Industry experts provide CCOs with a list of best-practice recommendations. To instill the ideal compliance culture, compliance officers have to exert as much energy in forging strong working relationships with their firm's boards as they spend assessing and mitigating the compliance risk of their firm's business activities, according to Jim Volk, chief accounting officer and CCO for SEI's Investment Manager Services unit.

"Based on the discussions that followed each presentation, it's clear that [chief compliance officers (CCOs)] |image1|have made great strides in implementing policies and educating senior management and their boards," says Volk, summing up a recent compliance forum sponsored by SEI, the Oaks, Pa.-based investment processing provider. "While there's still work to be done to make sure the compliance mindset permeates throughout an entire organization, CCOs overall have been diligent in using the resources they have to change the culture of their organization."

Recommendation v. implementation

In addition to SEI's own compliance specialists the forum's panelists and speakers included Joseph Carrier, v.p. and treasurer of T. Rowe Price, John Tesoro, a partner with KPMG, and John Ford of Morgan, Lewis & Bockius.

In sum, the speakers advised CCOs to make their annual board reports as a balance of summary information and in-depth detail, solicit out-of-meeting feedback from board members on their presentations, keep senior management in the loop, prioritize risks as a way to allot time and energy and help foster a work culture in which compliance considerations become an everyday part of doing business.

Finally, forum participants remind firms that, though it is indeed the CCO's role to make observations and recommendations, it is the job of senior management, with board guidance, to make sure those recommendations have teeth. -FWR

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