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July 31, 2003
TO: COMPLIANCE ADVISORY COMMITTEE No. 58-03
RE: DRAFT COMPLIANCE FUNCTION SURVEY - COMMENTS REQUESTED BY
AUGUST 25TH
At a meeting of the Compliance Advisory Committee last year, members discussed the
possibility of conducting a survey of how the compliance function is organized and staffed at
different firms. The Institute established a working group of members and, with this group’s
assistance, has prepared a draft survey, a copy of which is attached. The survey is designed to
elicit information on issues such as how firms staff their compliance function, the content and
frequency of compliance monitoring, use of automation in the monitoring process, and how
responsibilities for various compliance functions are allocated among different areas of a firm
(e.g., compliance, legal, operations, and risk management departments).
The Institute is interested in receiving members’ input on all aspects of the draft survey.
In particular, we would like your views on: (i) whether the survey adequately accommodates
your firm’s organizational structure; (ii) whether the scope of the questions is appropriate (for
example, the current draft is not limited to mutual fund compliance); (iii) whether there are any
compliance functions that should be added to, or deleted from, the survey; and (iv) whether the
survey will elicit useful information and will not be unduly burdensome to complete.
Please provide any comments or questions you may have on the draft survey to Barry
Simmons at (202) 326-5923 (phone), at (202) 326-5827 (fax), or at bsimmons@ici.org (email), or to
Frances Stadler at (202) 326-5822 (phone), at (202) 326-5827 (fax), or at frances@ici.org (email), by
Monday, August 25, 2003. We anticipate that once the comments are received, and any
necessary modifications to the survey are made, we will forward it members for completion.
Barry E. Simmons
Associate Counsel
Frances M. Stadler
Deputy Senior Counsel
Attachment (in .pdf format)