Client Advisories and Bulletins

Advisers Must Have Written Compliance Policies And Procedures Under New SEC Rules

December 2003
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The Securities and Exchange Commission recently adopted a new rule that will require registered investment advisers to

  • adopt and implement written policies and procedures reasonably designed to prevent violations of lawby the adviser and its supervised persons, 
  • review annually the adequacy of the policies and procedures and the effectiveness of their implementation, and
  • appoint a Chief Compliance Officer to be responsible for administering the policies and procedures.

There will be a nine-month phase in period for new Rule 206(4)-7 to enable advisers to prepare and implement written policies and procedures. The compliance date will be October 5, 2004, nine-months after expected publication of the rule in the Federal Register. By the compliance date, advisers are required to have adopted their written policies and procedures and appointed the Chief Compliance Officer. The first annual review of the policies and procedures is to be completed no later than 18 months after their adoption.

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