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U.S. Securities and Exchange Commission

Compliance Outreach Program

for Investment Advisers and Investment Companies

National Seminar Agenda
(Discussions Directed Towards Larger Firms)

January 31, 2012

7:30 am


8:30 am

Welcoming Remarks — Chairman Schapiro

8:45 am

Introductory Remarks

Carlo di Florio, Director, Office of Compliance Inspections and Examinations
Eileen Rominger, Director, Division of Investment Management

9:15 am

Compliance and Enterprise Risk Management

  • How Risk Management and Compliance Intersect to Effectively Identify, Assess, and Manage Risk within the Regulations
  • Align Risks: How CCOs Can Leverage and Engage Operational Units in Their Firms
  • Communicating Control Activities to Document, Report, and Attest to the Effectiveness of Policies and Procedures

Drew Bowden, Associate Director, Office of Compliance Inspections and Examinations
Kevin Goodman, Associate Director, Denver Regional Office
Philip Kirstein, Independent Compliance Officer and the Senior Officer, AllianceBernstein
Joseph Carrier, Chief Risk Officer, Legg Mason, Inc.

10:30 am


10:45 am

Trading Practices

  • Risk Management:
    • Managing the Full Range of Potential Events
    • Keeping Investment Information Protected from Misuse Within A Firm and Confidential From External Sources
    • Using Expert Networks, Affiliations, Relationships, and Consultants
    • Using Alpha Capture Systems
  • Align Risks so that CCOs Can Identify:
    • Potential 204A-Related Issues
    • Misuse of Material Non-public Information
    • Insider trading
  • Communicating Control Activities: Tools to Detect and Address Misconduct

Erozan Kurtas, Senior Specialized Examiner, New York Regional Office (see slide presentation)
David Grim, Assistant Director, Division of Investment Management
Charles Senatore, Head of Corporate Compliance, Fidelity Investments
Jennifer Duggins, Compliance Officer, Chilton Investment Company, LLC

12:00 pm

Lunch Break

1:30 pm

Dodd-Frank Wall Street Reform and Consumer Protection Act

  • Rules Implementing Amendments to the Advisers Act
  • Transition of Mid-Sized Advisers from SEC Registration to State Registration
  • New Registration and/or Reporting Requirements for Private Fund Advisers
  • Enhanced and/or Mandatory Collaboration with Other Regulators
  • Changes to the National Exam Program as a Result of New Regulations

Norm Champ, Deputy Director, Office of Compliance Inspections and Examinations
Robert Plaze, Deputy Director, Division of Investment Management
Thomas Kennedy, Chief Compliance Officer of Arden Asset Management, LLC
Eric Komitee, General Counsel, Viking Global Investors, LP

2:45 pm


3:00 pm

Enforcement-Related Matters

  • Discussion with Enforcement’s Asset Management Unit
  • Trends and Messages in Recent Enforcement Matters
  • Reflecting on Enforcement Matters Where the CCO is Named

Rosalind Tyson, Regional Director, Los Angeles Regional Office
Barbara Chretien-Dar, Assistant Director, Office of Enforcement Liaison, Division of Investment Management
Bruce Karpati, Co-Chief Asset Management Unit, Division of Enforcement
Robert Kaplan, Co-Chief Asset Management Unit, Division of Enforcement

4:15 pm

Safety and Soundness of Client Assets/Custody

  • Lessons Learned from Implementing the New Custody Rule
  • Asset Verification within the National Exam Program
  • Custody Issues Associated with Terminated Funds and Funds-of-Funds (i.e. funds that are winding down)

Donna Esau, Assistant Director, Atlanta Regional Office
Daniel Kahl, Assistant Director, Division of Investment Management
Nancy Morris, Executive Vice President, Allianz Global Investors of America
Lee Augsburger, Senior Vice President, Chief Ethics and Compliance Officer, Prudential Financial

5:25 pm

Closing Remarks

Carlo di Florio, Director, Office of Compliance Inspections and Examinations



Modified: 01/27/2012