Memo #
28975

Service Provider Oversight Resources Available to CCO Committee Members on the ICI's CCO Committee Webpage
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[28975]

May 12, 2015

TO: CHIEF COMPLIANCE OFFICER COMMITTEE No. 4-15 RE: SERVICE PROVIDER OVERSIGHT RESOURCES AVAILABLE TO CCO COMMITTEE MEMBERS ON THE ICI'S CCO COMMITTEE WEBPAGE

 

As you may recall, earlier this year, the Institute asked members of the CCO Committee to share with the Institute copies of any documents (questionnaires, check lists, due diligence lists) that members were using to oversee their variety of service providers.   The request was made so ICI could compile the submissions and share them with the Committee as a resource.  Members generously shared their documents and we have compiled them into a document, “Compilation of CCO Compliance Resources.”  This Compilation, which runs over 250 pages, is available on the Committee webpage at: http://www.ici.org/committees/chief_compliance_officer.   You will find the link to this document at the bottom of the Committee landing page under “Links to Resources.”  Please note that only members of the CCO Committee have access to the Committee’s webpage.

The Compilation is divided into seven sections, which each focuses on documents relating to a particular type of service provider.  The service providers included in the compilation include fund administration, accounting, transfer agent, custodian, subadvisers, distributors, expert networks, blue sky administrators, pricing vendors, AML services, and distributors of managed pool vehicles. 

In addition to the Compilation, we have also posted the following on the Committee’s webpage:

  • The CCO Intermediary Certifications, which we collected from Committee members last year (and previously circulated to members of the Committee via a PDF file);
  • Information the Institute published in May 2006 to assist members in overseeing their subadvisers;
  • A link to the ICI’s Resource Center on Information Security, which includes a variety of resources to assist members and their boards in their efforts relating to information security concerns, including cybersecurity; and
  • The SEC Risk Alert listing the areas of focus for the SEC’s cybersecurity sweep examinations last year.

The Committee’s webpage also includes a list of, and the contact information for, all members of the Committee, information on any upcoming meetings, and a list of recent memos sent to the Committee.  Note that the Committee roster can be viewed either alphabetically or by company.

I hope you find these resources helpful to you.  If you have any suggestions for other information that should be posted on our webpage, please let me know.  Thanks to each of you who have shared information with the Institute to assist us in producing these documents as a resource to your colleagues on the Committee!  Thanks also to my assistant, Jennifer Odom, for redacting any identifying information from these documents and doing such a great job of organizing and consolidating them!

 

Tamara K. Salmon
Associate General Counsel