The survey was conducted online from
This year’s survey addressed compliance testing with respect to the following areas: cost of compliance, document retention and destruction policies, fees and expenses, directed brokerage, soft dollars, and conflicts of interest, as well as the impact of CFTC registration and FATCA regulations. The survey also contained trend update questions about social media, anti-money laundering, business continuity and disaster recovery planning, and hot compliance topics.
Key findings include:
• Since last year’s survey, compliance testing has increased the most in the areas of advertising and marketing, personal trading, disaster recovery planning, and political contributions/pay to play.
• 79% of firms indicated that they have not decreased compliance testing in any area.
• 32% of the firms reported having only one person in a full-time legal/compliance role.
• 63% of CCOs are wearing two or more hats.
• 99% of firms reported that they do not outsource the Chief Compliance Officer (CCO) role.
• 68% of firms reported that their CCO is a senior executive in the firm.
• 8% of firms reported detecting material compliance issues – and 22% reported finding no compliance issues. The most common material issues were in the areas of advertising and marketing, personal trading, client guidelines, and custody.
• Advertising and marketing is the “hottest” compliance topic cited in the survey, followed by valuation and social media.
• 83% of firms have adopted formal written policies concerning social networking, up from 64% in 2011 and nearly double the percentage of 43% in 2010.
• 49% of firms prohibit the use of personal social media sites for business purposes, down from 54% in 2012, and 43% report that their social media testing has increased in the past year.
• FATCA and CFTC/NFA registration requirements have increased the already heavy workloads of many compliance staffs.
“The survey confirms that investment advisory compliance professionals continue to adapt their firms’ compliance programs to address the progressively complex regulatory environment,” said
“We recognize that we are in an industry held to very high standards that takes its compliance responsibilities very seriously. This is evidenced by the remarkably high response rate the survey continues to have year after year, the trends coming out of the survey, and the thoughtful responses of the survey participants,” noted
“The survey results reflect what ACA consultants have seen in practice: continued emphasis on the creation of testing programs and new methods to detect deficiencies and continued concern regarding compliance surrounding advertising, marketing and social media,” said ACA Compliance Group Managing Director
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About the Survey Organizers:
Old Mutual Asset Management
OMAM is a global multi-boutique investment organization, managing and growing a diverse portfolio of asset managers that serve institutional investors around the world. The assets under management of OMAM’s affiliated investment firms were
Old mutual provides life assurance, asset management, banking and general insurance to more than 14 million customers in
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