PLI Advanced Compliance Workshop: The Changed Face of Compliance

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PLI Advanced Compliance Workshop The Changed
Face of Compliance

• Autumn 2009

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The Changed Face of Compliance

• Regulators Increased Enforcement Budgets
• Increasing Enforcement Expenses by Agency Page 2
• SEC FY 2010 Page 3
• DOJ FY 2009 Page 4
• FDIC FY 2009 Operating Budget Page 5
• Compliance Stakeholders Changing Pressures
  Needs
• Board of Directors Page 7
• Senior Management Page 8
• Regulators Page 9
• Line Business Management Page 10
• Other Staff Functions Page 11
• Shareholders Page 12
• Customers Page 13
• Suppliers Page 14
• Client Services Department Page 15

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Compliance Stakeholders changing pressures
needs
Suppliers
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Compliance Stakeholders Board of Directors

• Pressures
• Regulatory scrutiny.
• Increased shareholder activity.
• Federal Sentencing Guidelines.
• Change!
• Needs
• Find problems early.
• Identify and evaluate potential issues.
• Escalate if necessary.
• Clearly articulate resource needs.

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Compliance Stakeholders Senior Management

• Pressures
• Revenues dropping, costs savings, reduced
  budgets?
• Planning for the future.
• Increased focus from board and regulators.
• Change!
• Needs
• Professionals who understand the business.
• Find problems early.
• Identify and evaluate potential issues.
• Escalate if necessary.
• Clearly articulate resource needs.

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Compliance Stakeholders Regulators

• Pressures
• Public asks, Where were they?
• Congressional scrutiny and changes to the
  regulatory structure.
• Enhanced enforcement budgets.
• Conflicting concerns and accountability from
  public, press, regulated.
• Rebuilding reputation.
• Needs
• Provide tangible evidence of effective program.
• Help leverage their own resources.
• Training and insight into changes in the
  business.
• Understand the pressure they are under.

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Compliance Stakeholders Line Business Management

• Pressures
• Grow revenues/ limit expenses.
• Potential for more fraud.
• Change, more stress!
• Lack of training.
• Insecurity increases risk that issues are not
  surfaced.
• Needs
• Confidence that identified risks and exposures
  are appropriately prioritized.
• Efficiency and fairness in compliance
  investigations.

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Compliance Stakeholders Other Staff Functions

• Pressures
• Increased workloads changing rules and product
  lines.
• Possible budget reductions.
• Pressures from various stakeholders.
• Needs
• Synergies in working together.
• Help in arguing a case when help is needed.
• Confidence compliance is doing its job.

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Compliance Stakeholders Shareholders

• Pressures
• Post-Madoff panic persists.
• Liquidity.
• Transparency.
• Do companys public disclosures reflect risks of
  investing?
• Needs
• Robust Compliance program.
• Positive legal and compliance culture.
• Find problems early.
• Identify and evaluate potential issues.
• Escalate if necessary.
• Clearly articulate resource needs.
• Confidence compliance is doing its job.

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Compliance Stakeholders Customers

• Pressures
• Concerned about what they can rely on are there
  even assets there?
• Comforted by a strong compliance department.
• Needs
• Comfort.
• Compliance becomes a plus in the marketing
  process.

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Compliance Stakeholders Suppliers

• Pressures
• Heightened attention to government contractors
  andtheir suppliers.
• Rapidly changing laws and regulations.
• Customer Relations.
• Needs
• Need to comply with customers codes or their own
  codes.

Suppliers
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Compliance Stakeholders Client Services
Department

• Pressures
• Increased and proactive due diligence by
  prospectiveinvestors, clients and consultants.
• Sufficient resources.
• Demand for accuracy.
• Balance fiduciaries obligations with firms
  confidential and proprietary information.
• Needs
• Adequate training by compliance professionals.
• Regular review of oral and written communications.

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Deborah Prutzman Chief Executive
Officer dprutzman_at_regfg.com O 212 537 4058 M
917 887 6347
RFG combines timely and comprehensive
regulatory, compliance, and risk management
support with strategic business advice to
deliver action-oriented solutions.