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RCW Staff

When Victoria Hogan served as an SEC examiner, she often discovered deficiencies simply when interviewing a firm’s traders. That’s why she advises compliance officers do ...
This is an example of an escalation policy designed to help a firm direct whistleblower claims up the ladder. This was prepared by Patricia Foster, ...
Jill Grenda, managing director at Hardin Compliance Consulting outside Pittsburgh, kindly shares her BCP Checklist
A peer shares this P&P
This is a matrix for an enterprise risk management structure within a firm, courtesy of Fred Shane, former chief risk officer at Commonwealth Financial Network ...
These records should be kept 'true, accurate and current' and must be held for five years
This is an example a peer shares of a non-disclosure agreement
This is a peer's questionnaire for quizzing its subadvisers
As you dig deeper into your conflicts inventory, conduct a 'gap analysis' to identify instances where you lack policies and procedures
This is the Advisers Act's books and records rule

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