SEC's Bowden: Ethical Standards More Important Than Policy, Procedures
Having an “ethical standard” is the most important part of an advisory firm’s compliance policy, Andrew Bowden, head of the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations, told compliance officers Tuesday.
“In order to be compliant, [advisory firms] can’t be effective by merely having policy and procedures, even if tested,” Bowden said during a question and answer session with Chuck Senatore, head of compliance and ethics at Fidelity Investments, during the National Society of Compliance Professionals’ annual conference at National Harbor, Maryland, just outside Washington.
Bowden said his “No. 1” piece of advice for firms is to “decide the [firm’s] ethical standard; there is no law surrounding” that. Firms should “decide why we are engaged in this endeavor,” and be able to articulate it. Bowden said he queries CEOs on this question when conducting exams. Read more on ThinkAdvisor.