Securities Activities of Banks in the GLB Era - Cleary Gottlieb Steen ...

(B) Confers with and advises senior management
on significant compliance matters and issues,
ensures that there is timely and appropriate
review of material and repetitive compliance
issues as indicators of possible weaknesses in
policies or risk identification processes, and
facilitates the use of such information in
keeping the adviser compliance program
evergreen.
(C) Provides “consulting” to business people
throughout the adviser regarding compliance
matters and issues and becomes involved in
analyzing and resolving significant compliance
issues.
(D) Ensures that the steps in the adviser’s
compliance process -- risk identification,
establishing and implementing policies -- are
appropriate and are undertaken timely; and
ensures that appropriate principles of
management and control are observed in policy
implementation (including separation of
functions, clear assignment of responsibilities,
measuring results against standards, reporting
outcomes and regular reviews).
(E) Ensures that compliance policies are
comprehensive, robust and current, and reflect
the adviser’s business processes and conflicts
of interest; and manages the compliance unit in
ways that encourage pro-active work,
professional skepticism, and “thinking outside
the box” by compliance staff.
(F) Ensures that quality control (transactional)
testing is conducted as appropriate to detect
deviations of actual transactions from policies
or standards, and that results of such tests are
included on exception and other management
68