Budget season is nearing an end – are you ready for what’s ahead?
Mark Twain once said, “Never put off till tomorrow what may be done day after tomorrow just as well.” With six weeks left in the year, there is no time to put off completing certain Compliance tasks. Many firms are scrambling to complete their branch exams, mock audits, AML testing, continuing education requirements, looking at tax strategies and compensation plans….the list seems endless. In this “broken windows” regulatory environment, you have to be flawless in your execution of these tasks.
But planning for the coming year is important, and now is the time. At Oyster, we believe that the best financial services organizations in the world make decisions with the input of the strategic leaders, sales, operations, trading, technology, finance, compliance, risk and legal groups. Your leadership needs to be discussing your firm’s needs for technology, people, and services in the coming year. You also need to be evaluating the marketplace for changing pricing structures and potential regulatory shifts. Dodd-Frank, the Volcker Rule, cybersecurity, Reg SCI, CAT and DOL fiduciary standards have all been talked about extensively, and you should have plans in place to deal with the evolving landscape.
Don’t forget to expect the unexpected. You may have heard rumors that the SEC may be proposing a rule that will require investment advisers to hire outside reviewers (such as Oyster Consulting) to conduct annual reviews of firms’ compliance systems. This week, SEC Chair White confirmed the rumor in testimony she gave on Capitol Hill. The financial impact: firms will need to budget for such reviews, as soon as in their 2016 budgets. In addition, any reports done by the reviewers will be subject to SEC discovery. The SEC will also likely prescribe what needs to be tested during the reviews, and finally, an assumption can also be made that any findings will need to be closed out before the next review occurs.
Building a healthy company requires planning, execution, and keeping your eye on the ever changing business, technology and regulatory landscape. Oyster Consulting is ready to help, allowing your firm to do what it does best.