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Compliance

June-12-17

What’s a Chief Compliance Officer … and What’s It to You?

As PWL Capital’s Chief Compliance Officer (CCO), I’ve been sharing informative blog posts for a while. Recently, it struck me: I’ve never talked about what a CCO is or, more to the point, why you might care whether I’m any good at the job.

To put my role in context, think of it as being like the head lifeguard at a busy beach:

Nobody Notices Us, Until …

Have you caught this summer’s remake of the 1990s TV show Baywatch? I think we both know there’s the fantasy, Hollywood version of a lifeguard, entailing hot romance and heroic action. Then there’s the real-life duty, involving hundreds of hours of unglamorous and uneventful vigilance, while everyone else is splashing in the sunny surf.

Like a real-life lifeguard, if I’m doing my job properly, you’ll barely notice I’m around … until you need me. My duty and privilege is to ensure firm-wide adherence to our own best practices, as well as to the countless external regulations designed to protect investors (YOU) from any financial industry malfeasance. I do my level best to head off any problems before they sneak up on us, and to report anything that might slip past. This means …

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We’re Always Ready To Roll

My colleagues and our clients alike depend on my remaining ever-ready to spring into team-oriented action as needed. Thankfully, we run a tight ship around here so, most of the time, everything’s fine and we’re all busy serving our clients. But a bounty of external regulations and in-house ideals results in a sea of policies and procedures to watch over. Every so often, a big wave of new requirements comes along – such as this year’s new CRM2 regs. Then, it’s all hands on high alert!

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Beefed Up Expertise Is Essential

Admittedly, when it comes to actual brawn, I’m not quite on par with a bench-pressing movie star. But as required and desired for a CCO, I try to stay seriously pumped with ongoing education and hands-on experience. To become CCO, I first had to pass several Canadian Securities Institute exams, including the Canadian Securities Course; Conduct and Practices Handbook Course; CCO Qualifying Exam; and Partners, Directors and Senior Officers Course. Ongoing, I also remain current on all IIROC (investment industry), FINTRAC (anti-money laundering), and the Canadian Privacy Act rules. Trust me, there’s a lot of fine print in those rules, which means …

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There’s Never a Dull Day

My favorite thing about being CCO is also one of my greatest challenges. Every day is different. New regs, questions, projects … something’s always surfacing in our nimble little firm (“little” compared to the big banks, anyway). I love that about my job. Here are a few ways I stay busy:

  • Keeping current on regulations – updating, adjusting and informing my colleagues as needed.
  • Promoting a firm-wide and individual culture of compliance; promptly alerting our President and our CEO to anything that could put our clients or their investments at risk.
  • Reviewing essentially every new account, existing client portfolio, client-signed document, and daily trading ledger for accuracy and respect of our policies.
  • Reviewing essentially all of PWL’s individual and broadcast communications – handouts, presentations, blogs, videos, newsletters, social media posts, etc. etc. etc.
  • Ensuring there’s backup support if I’m unavailable, serving as a liaison with our regulatory agencies and managing periodic audits.

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We’re Good Cop and Bad Cop

Just as a lifeguard can be your pal most of the time, but more like a police force if you are putting yourself or others at risk, my role at PWL can be delicate. From the top down, we take compliance very seriously, so I usually get to be the good cop. But every so often I must call out an otherwise well-intended move that may have gotten a little ahead of the fast-evolving rules and regulations. “Bad cop” is not my favorite role, but again, we’re all in this together so everyone is pretty understanding when it happens. Plus for me …

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It’s Personal

We CCOs are not only professionally responsible to uphold our firm’s compliance, we can be held personally liable should anything go wrong. As CCO I’m also a director at PWL, as is required for the position. By intent, every financial firm must have a CCO, and every firm’s CCO must have lots of his or her own skin in the game.

Besides all that, I just plain care. As crushed as a lifeguard would feel if somebody ever got hurt on their watch, that’s how bad I would feel if a compliance breach I could have prevented were ever to cause anyone any harm.

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It’s Fulfilling

It may seem like the financial industry has a lot of mundane rules, regulations and red tape that we’re forever fussing over. To me, they’re not mundane at all, and there’s good reason to fuss over them. Ultimately, those rules are here to protect YOUR financial well-being, and I’m here to ensure we’re fully adhering to them. I’m grateful I have all the support that I do, so I can do my job properly on your behalf. This is a role I relish … even if it doesn’t afford me an awesome ocean view.

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By: Jennifer Vachon | 0 comments