The regulatory landscape for the financial industry has changed dramatically since the passing of the
Dodd-Frank Act in July 2010, demanding even greater collaboration between management and
compliance professionals to help ensure that a firm’s compliance program is effectively designed to
prevent violation of federal and state securities laws. With the advent of the SEC’s risk-based
examination program, district office examiners are turning their attention on firms that have higher risk
profiles as measured by their registration filings, reporting documents and prior examination deficiencies
in order to focus attention on potential transgressions. Importantly, a firm’s culture of compliance and
particularly its “tone at the top,” must be supported by senior management, whose commitment is critical
to the long-term success of the enterprise. Today, compliance efforts must not only reside with
designated compliance officers but with every member throughout the organization.
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