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

eports and are promptly addressed, escalated
when necessary, and resolved by responsible
business people.
(G) Undertakes periodic analyses and evaluation of
compliance issues found in the regular course,
together with the results of appropriate forensic
testing conducted by compliance staff as a
means for obtaining evidence regarding both
the effective functions of the adviser’s
compliance program and the possible existence
of compliance issues.
(H) Ensures that compliance programs of service
providers used by the adviser are effective so
that the services provided are consistent with
the adviser’s fiduciary obligations.
(I) Establishes a compliance calendar that
identifies all important dates by which
regulatory, client reporting, tax and compliance
matters must be completed.
(J) Promotes a process for regularly mapping the
adviser’s compliance policies and conflicts of
interest to disclosures made to clients, so that
disclosures are current, complete and
informative.
(K) Manages the adviser’s code of ethics.
(L) Is a strong advocate for allocating appropriate
resources to the development and maintenance
of an effective compliance program.
(M) Recognizes the need to remain current on
regulatory and compliance issues, participates
in continuing education programs, and ensures
that staff is appropriately trained in
compliance-related matters.
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