Compliance
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Compliance

Representative Engagements

Compliance is one of the top risks financial institutions face. At Promontory, global compliance risk management is central in our daily focus, including:

 


  • Compliance Program Design
    • Compliance Risk Governance
    • Policies and Procedures
    • Compliance Obligation Libraries
    • Compliance Risk Assessment Methodologies and Systems
    • Compliance Monitoring Programs and Systems
    • Compliance Issue Tracking Systems
    • Compliance Risk Reporting Packages for Board-level and Senior Management Reporting

  • Compliance Program Implementation
    • Compliance Staffing Plans
    • Temporary Compliance Staffing
    • Including Compliance Risk Management Objectives in Compensation Plans

  • Compliance Program Review and Testing
  • Investigation and Remediation of Compliance Lapses
  • Compliance Training Design and Delivery
    • Board-level Training
    • Employee Training (in-person and computer-based)
    • Specialist Training

Promontory’s compliance practice clients include investment advisers, hedge funds, investment companies, broker-dealers, securities exchanges, banks, insurance companies, and other public and private companies.

At the core of our practice is our grasp of the ever-greater challenges imposed on compliance officers. Our professionals, with long careers as corporate executives and senior-level regulators, have designed and operated compliance systems and have written and implemented regulations. Our advice is informed by our knowledge of evolving regulatory expectations and is mindful of the operational and structural challenges that compliance officers face in the current environment. We manage compliance crises, conduct special reviews, and develop thorough and efficient compliance programs.

In addition to general compliance work, we provide specialized advice in six specific areas:

Representative Engagements

  • Promontory implemented a compliance risk assessment using our proprietary software for a large financial institution that was facing a downgrade of its regulatory rating for compliance risk management.  Regulators cited the risk assessment as the reason the institution avoided the downgrade.
  • Promontory completed regulatory compliance review and restructured of one of the world’s largest nonbank financial services providers, with in-depth focus in the areas of anti-money laundering, the Bank Secrecy Act, and “Know Your Customer” requirements, helping the institution avoid onerous enforcement penalties.
  • A US state regulator required a large broker-dealer and investment adviser to hire an independent consultant to assess its controls over the use and protection of customers’ personal and financial information. Promontory was engaged to conduct a review of relevant policies, procedures and practices. We assessed the effectiveness of the design and implementation of existing policies, procedures and related practices to determine compliance with state and federal law, including the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (SEC) Regulation S-P. Promontory reported its findings and recommendations to the client and to the government regulators.
  • A registered investment adviser to multiple hedge funds turned to Promontory for a review of its compliance systems and written compliance policies and procedures. We assessed the operational effectiveness of compliance policies, procedures and systems, and made recommendations to fulfill regulatory requirements and to meet industry best practices. Throughout the review, Promontory gave real-time advice to the client on compliance and regulatory issues and provided guidance to the client and its attorneys on working relationships with the SEC’s examination of enforcement staff.