Standard Tuition $400 US
Senior Fellow Michael Sherman, JD, Partner, Dechert
Rule 206(4)-7 under the Investment Advisers Act of 1940 (the “Advisers Act”) requires an investment adviser registered with the Securities and Exchange Commission (“SEC”) to adopt and implement written policies and procedures reasonably designed to prevent violation, by the adviser and its supervised persons, of the Advisers Act. In addition to requiring registered investment advisers to adopt written compliance policies and procedures and appoint a chief compliance officer, Rule 206(4)-7 requires a registered investment adviser to review its compliance policies and procedures annually to determine their adequacy and effectiveness. As part of its annual review, an investment adviser must consider any compliance matters that arose during the previous year, any changes in the business activities of the investment adviser or its affiliates, and any changes in the Advisers Act or applicable regulations, that might suggest a need to revise the policies or procedures. The investment adviser also must keep records documenting such annual review.
The SEC staff views the annual compliance review as a key element in ensuring that an investment adviser has implemented an effective compliance program and focuses significant attention to the annual review results and process when it examines advisers. Accordingly, investment advisers and their compliance staff’s must understand the annual review proceed and it implications.
Students shall discover the following within this class session:
• Define the annual review required by the Rule.
• Examine the substantive scope of the annual review.
• Identify the staffing and other resources that an adviser will need to conduct the annual review.
• Identify and discuss best practices in conducting an annual review and SEC expectations.
• Examine strategies and related considerations for addressing identified compliance problems, including remedial actions.
• Recognize the importance of properly documenting the annual review and its results.
• Highlight “hot-button” compliance issues based on SEC guidance and recent examinations.
Senior Fellows from Practice:
- Michael Sherman, JD, Partner, Dechert
- Michael Donahoe, Chief Compliance Officer, PNC Capital Advisors
- Richard Horowitz, JD, Partner, Dechert
- Nauman Malik, JD, General Counsel & Chief Compliance Officer, Eagle Point
Credit Hours: 4
Subject Area: Professional Practice
States: Contact Curriculum Advisor For More Information
Credit Hours: 6
Subject Area: Accounting
States: Contact Curriculum Advisor For More Information
Course ID Number: 8501
Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits.
Arizona: Does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. RCA programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.
Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts.
Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit.
New Hamphsire: The approval is for three years from recorded date.
New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year.
New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web Programs or live Webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.
North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs.
Ohio: To confirm that the web program has been approved, please refer to the list of Ohio’s Approved Self Study Activities at http://www.sconet.state.oh.us. Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.
Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs.
Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour.
Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component.
Tennessee: The approval is for the calendar year in which the live program was presented.
Virginia: All distance learning courses are to be done in an educational setting, free from distractions.
Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts.
Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs.
If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.
If applicable, the RCA will apply for credit in your state upon request.