CCO Resource Hub: Members’ Compliance Manuals

Chief Compliance Officer Committee

Compilation of the Tables of Contents from Members’ Compliance Manuals

Overview

In the spring of 2017, the Institute asked the members of ICI’s CCO Committee to share with us copies of the Table of Contents of their Compliance Manual. It was hoped that a compilation of these documents would be a resource for members to both see the topics covered by other members’ manuals and to determine whether they had any gaps in their own manuals. When we reached out to members to share their Tables of Contents with us, we had 42 members respond. These members provided us copies of the table of contents for their funds’ and/or advisers’ compliance manuals. In order to provide some organization to the information we received, ICI’s Law Department Intern, Sue Lee, reviewed each submission to determine which provisions in them were common and which were unique. The submissions she reviewed are summarized and organized as indicated below. 

Organization of this Compilation

In order to increase the utility of this document to CCOs, these policies and procedures are organized as follows and in the following order:

• Summary of Common Provisions Found in Members’ Manuals. This document provides a list of provisions found in 90%, 70–90%, 50–70%, and 25–50% of manuals. It also includes a list of other common headings found in members’ manuals.
• An alphabetized listing of the subject matters covered by members’ policies and procedures.
• A listing of the subject matters covered by members’ policies and procedures organized by the number of firms (from the largest number to the smallest number) whose manuals addresses the subject matter.
• An alphabetical list of unique provisions in members’ Manuals. These provisions are those that are found in a very limited number of Manuals. The parenthetical following the provision indicates which Manual(s) includes the provision. [These unique provisions are not included in the spreadsheets that are part of this Resource.]
• Four spreadsheets listing the most common topics covered by members’ Tables of Contents and indicating (by a 0 in the column) which Manual includes which topics.
• The 43 Tables of Contents we reviewed (organized in no particular order). The names of members’ firms have been redacted from these documents to the best of our ability to ensure members’ anonymity.

As with all the documents we collect and post to our CCO Resource Page, we hope this information will assist members of the Committee in fulfilling their legal duties and obligations.

The documentation provided by ICI that may be accessed by committee and task force members is restricted to members use only and not for distribution or reproduction. Documentation may be used internally at member organizations as needed to facilitate committee and task force initiatives.