Elisse Walter, in a recent speech to NASAA voiced her concerns about the often ineffective compliance programs at smaller advisory firms. She said, "We recognize that small firms present special challenges. For example, many of them don't have comprehensive compliance programs in place. Many more have off-the-shelf programs that aren't tailored to their actual businesses." She further said that CCOs that have multiple job responsibilities "have too many priorities on their plates to devote adequate time to compliance efforts." Additionally, they have "conflicting responsibilities — concerns about cost, privacy, investment strategies and so on." She emphasized the benefits of continued cooperation and sharing between the SEC and the state regulator and stated that securities regulators need more resources to examine more advisers. One thing is clear from this speech, the SEC has concerns about small advisers and wants to help the state regulators get out and audit them effectively. To read the full speech, please click here.
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