News & Events

Corporate Senior Counsel Allison Bernbach was quoted extensively in a Hedge Fund Law Report article titled, “Preparing For and Facilitating the Digitization, Automation and Optimization of Compliance Programs.” The article summarized key takeaways from a recent ACA Group panel discussion that featured Allison, and highlighted preparation expectations for increasing digitalization of compliance, recommendations for regulatory examination responses, methods to leverage existing platforms and insights for choosing and implementing new technologies. Allison explained how technology enables compliance teams to respond to SEC exam requests more efficiently, and that while technology can aid in the preparation of documents by automating the process, it cannot be relied on entirely and should be monitored, stressing the importance of reviewing SEC requests, speeches, risk alerts and statements for guidance. In addition to a compliance team, Allison suggested robust training and dedicated time for compliance staff to help end-users ensure that compliance reporting is accurate and complete when using technology for tasks such as annual reporting. Once processes are automated, Allison explained that compliance teams must respond to reports, stating, “You do not want to have a failure to supervise because all of the reports generated showed a problem and you did not resolve it.” Similarly, she warned that it’s important to remember that the SEC has recently pursued pure policy and procedure cases in which there is no underlying “bad act,” and that technology can help compliance departments schedule reviews of their policies to show the SEC that they are dedicated to ensuring procedures are maintained and in compliance.

To read the full article, please click here (subscription required).