Annual Review
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1 Annual Review
1.1 Annual Review – CCO’s Role
The CCO will ensure that the firm’s compliance program is reviewed on an annual basis or more frequent basis. The primary focus of this review is to ensure that the written procedures are current and adequately address all areas of its business. The CCO will create a summary document in order to memorialize this review having taken place, and will provide a written synopsis of this analysis for record.
1.2 Policy Breaches
Any material breach of firm policy will be identified, mitigated and disclosed (when required). All policy breaches will be recorded by the CCO for future reference. The CCO should be prepared to report breaches and their mitigation steps to regulatory bodies as necessary.
1.3 Annual Reports and Record Retention
Internal annual reviews will be reduced to written report by the CCO or qualified designee. All firm reviews, examinations, risk assessments and supporting documents or records will be retained by the CCO for a period no less than five years from the date of the final report. All of these documents may be subject to review or discovery.