The SEC Exam Priorities 2023 report is here.
Each year, the Commission releases this report to share what it’s seeing in exams. Typically, some themes and common deficiencies emerge. Ultimately, the Exam Priorities report is an opportunity for your firm’s leadership and CCO to invest in addressing common deficiencies now to ensure your firm doesn’t exhibit those weaknesses at exam time.
Proactively addressing potential compliance deficiencies is crucial, but it’s not always easy. Compliance programs touch all areas of a firm, and without a comprehensive tech solution, things can quickly become unwieldy.
Orion Compliance offers a flexible, scalable, customizable solution that’s designed to adjust to suit your compliance program’s unique needs. And with on-demand reporting, you can quickly pull records and show your work to regulators.
Let’s explore the ten ways Orion Compliance can help you prepare for an SEC exam.
1. Manage Personal Trading
Orion Compliance streamlines the personal trading process for compliance officers and CCOs by establishing a direct data feed with institutions that hold your employees’ investments.
Your compliance team sees a stream of trading data directly within Orion Compliance, eliminating the need for collecting and uploading paper statements. Any employee can submit trade requests through Orion Compliance, and your team can review those within the platform’s workflow. If there are questions or concerns, your compliance team can discuss them with the employee directly in the app.
Orion Compliance also maintains records of all incoming data feeds, requests, and compliance team decisions and notes on trades.
2. Update and Share Policies and Procedures
As compliance expectations change and your firm grows, you may need to adjust your policies and procedures.
Once you’ve finalized the latest draft of any policies, procedures, or manuals, you can push the new version out to your team through Orion Compliance. The platform maintains a record of all previous iterations of the document, making it easy for your team to reference past guidelines and identify relevant changes in the latest draft.
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3. Customize Forms
There are dozens of ways forms can be helpful to CCOs in tracking compliance activities. The forms tool within Orion Compliance is customizable, allowing CCOs to use it when and where it’s needed.
You may choose to create custom forms to manage gifts and entertainment reporting, log attestations, track annual certifications, and more. Form responses are automatically stored in the system, so you can quickly identify missing responses and reference past submissions at any point in the future.
4. Use for Internal and External Compliance Matters
Your entire team can access Orion Compliance via desktop or secure mobile app, making it easy for them to manage forms, certifications, and all other vital compliance processes from anywhere.
But the solution has applications beyond your team, too. Whether you’re looking to address compliance needs with your vendors or clients, Orion Compliance can help.
The forms tool can be used with an external audience. You may, for example, use forms to log responses as part of the vendor due diligence process.
You can also put Orion Compliance to use in ensuring client-facing communications are appropriately managed. For example, you can track the annual distributions of Form ADV and your privacy policy through the tool.
5. Reduce Manual Monitoring
Many essential compliance processes require ongoing monitoring of vast swaths of data. The list is long, from watching employees’ personal trading to alerts for clients with potentially less expensive mutual fund share classes to beneficial ownership or large trade reporting.
When your compliance team is responsible for manual monitoring, it often happens retroactively; old data is scanned, and only then are exceptions identified. Orion Compliance allows you to monitor crucial data feeds proactively to identify potential risks in real-time.
In the case of SCSD monitoring, for example, Orion Compliance integrates with Orion Risk Intelligence to scan for potentially less expensive share classes. You receive an alert when one is identified so you can act accordingly. Orion Compliance also allows for documentation of what’s most appropriate for your client and why.
6. Adjust as Regulatory Guidance Changes
The SEC new marketing rule was called out within the SEC Exam Priorities 2023 Report as an area of focus. Firms are still adjusting to this significant shift in regulatory expectations. As part of the process, they’re updating policies and procedures, educating staff about changes, and implementing new testing.
Orion Compliance makes getting your team up to speed on the latest regulatory expectations easy. You can begin by uploading the latest version of your compliance policies and procedures and pushing it out to your team.
You can manage team training through the platform, testing all employees on the updates to the SEC’s expectations and your internal policies.
Then, you can adjust existing forms to account for new needs. In the case of the SEC new marketing rule, you may add further questions or requests for advisors submitting marketing materials to your compliance team for approval.
Finally, you’ll have a central location to store all these new documents, forms, and related work. If regulators request reports showing the changes you’ve made to your marketing policies, you can pull them easily from within the Orion Compliance system.
7. Establish a Command Center for Your Compliance Team
Orion Compliance provides CCOs and other compliance officers with a comprehensive dashboard for managing all necessary compliance tasks. You’ll get a consolidated view of all testing, certifications, and reporting.
The calendar tool is handy in ensuring your entire team remains on top of vital compliance tasks. The Orion Compliance calendar allows you to schedule testing and certifications across your team. You can adjust due dates, send reminders, and track the completion status of all events.
This provides you crucial visibility into your team’s compliance standing and empowers you to follow up with anyone who may be behind in hitting critical compliance-related deadlines.
8. Watch Your Risks
No two firms are alike, and the risk module within Orion Compliance allows each CCO to identify and manage the risks that are most relevant to their firm.
Within the module, you can spell out major risk categories and assign risk weightings to each. Then, place controls within the system to mitigate those risks, identify the parties responsible for each control and assign them relevant tasks.
This centralizes all of your risk mitigation efforts, allowing CCOs and firm leadership to easily check in on the status of the risks of greatest concern.
9. Get On-Demand Reporting
When the regulators approach you with a document request, time is of the essence. Orion Compliance allows you to pull the documentation regulators seek in minutes.
And with the ability to slice and dice the data, CCOs can create reports that address the exact requests from regulators. Pull reports by date range and filter by parameters like officer, status, and category to ensure you share only relevant information.
10. Create a Culture of Compliance
One of the most essential things a CCO can do to ensure their firm remains audit-ready is to create a culture of compliance. There are no hard-and-fast rules for building one; it is more about imbuing all aspects of your team’s daily work with a compliance mindset.
An end-to-end regtech tool like Orion Compliance can help cultivate such a culture by ensuring compliance policies, procedures, and workflow are fully integrated into every aspect of your team’s efforts.
With a comprehensive compliance platform, achieving proper compliance becomes an essential part of daily work. And an integrated solution makes it easy for your team to follow through on compliance activities; it’s not an afterthought — it’s front-and-center in their day-to-day efforts.
Is your firm prepared to address the regulatory concerns outlined in the 2023 SEC Exam Priorities report? Contact our team today to learn how Orion Compliance can help you get audit-ready.
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