In a national sweep inspection begun at the end of October 2004, Securities and Exchange Commission staff began telephoning investment companies to gauge their compliance with the SEC's new chief compliance officer ("COO") rules.  We understand those surveyed were asked to describe the firm's risk assessment process-both in terms of the initial design of the compliance program and identification of new risks going forward-and also to discuss among other things.

Download PDF: Implementing and Reviewing SEC-Mandated Compliance Programs