Regulatory Compliance Association Reviews

Compliance Program Transparency™ Series – Session 2

Practice Edge 02

Date: April 12, 2016
General Session: 12 Noon to 1:30 PM EST
Location: Webcast (Free)

Interested in CCE (Continuing Compliance Education)™, CLE or CPE (A & A hours)?

Become a Practice Edge Elite Member

In 2016, the competition for Institutional Investor allocations continues to intensify.

Recently, many asset managers have discovered a new hurdle: “Compliance Program Transparency™.” Previously, alternative investment and asset management firms could satisfy a due diligence inquiry regarding their compliance program with either:

  • A short meeting about the compliance program
  • Furnishing the Table of Contents from the compliance manual
  • An onsite review of the compliance manual

Unfortunately, the escalating enforcement environment generates an even greater “head line” risk for Institutional Investors – which supersedes investment return.

Consequently, an increasing number of Institutional Investors have requested more substantive and documented access to a firm’s compliance program.

In order to assist fund and asset managers successfully hurdle this emerging obstacle, and win allocations – the RCA created a 2 step, quantitative process, which independently validates a firm’s compliance program:

  1. Compliance officers adopting the RCA’s Compliance Officer Professional Code of Conduct, and
  2. The Alternative Investment or Asset Management firm adopting CFA Institute Asset Manager Professional Code of Conduct® (AMC)


Previously, properly adopting CFA Institute Asset Manager Professional Code of Conduct required an outside consultant or large commitment of internal resources.

In 2015, CFA Institute consulted with the RCA to deliver a 5 part AMC Implementation Series and to build an implementation and training platform. This initiative provides a step-by-step tutorial, and furnishes the RCA’s 350 page Model Compliance Manual to greatly reduce the time, effort and expense of this undertaking. Now a CCO or GC can “staff out” the entire process to in-house personnel and the RCA.


Implementing the AMC Section B – Investment Process and Actions

  1. Standard of Care
  2. Market Manipulation
  3. Fair Dealing
  4. Reasonable Basis
  5. Single Mandate Suitability
  6. Separate Account Suitability

Session Chairman:

Walter Zebrowski, JD, CPA, Principal, Hedgemony Partners
Chairman, Regulatory Compliance Association

Senior Fellow from Practice:

Jane Stafford, JD, General Counsel, Regulatory Compliance Association


James Jones, CFA, Founder/Portfolio Manager, Sterling Investment Advisors
Lynn Blake
, EVP, CIO for Global Equity Beta Solutions, State Street Global Advisors
Gerald Lins
, JD, GC, Voya
Jack Slusarczyk, Vice President, National Accounts & Institutional Sales, Excel Funds

Register Now