How to Build an Effective Compliance Calendar
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The Foundation: Rules and Risk Assessments
In the dynamic world of regulatory compliance for wealth management firms, having a well-structured compliance calendar is not just a best practice—it’s essential. A strong, tailored compliance calendar ensures that your tasks, reviews, and compliance filings are executed on time, minimizing risks and keeping your firm in line with regulatory compliance requirements. Constructing an effective compliance calendar requires a blend of regulatory knowledge, risk assessment, and operational planning.
Understand the Link Between Rules and Risk
The first step in creating a compliance calendar is to understand the regulations governing your broker dealer or investment advisor, and the associated risks. New regulations can require new policies, procedures, controls, testing, documentation, and, in some cases, designation of a new compliance role.
Conduct a Risk Assessment
Risk assessments play a pivotal role, especially when new regulations emerge. By analyzing the regulatory environment, existing controls, and the severity of penalties, firms can gauge the frequency and focus of compliance activities. Risk assessments identify conflicts of interest and risk factors that might create risk exposure to your firm or your clients. Are there new lines of business? New products? New types of clients? New employees who aren’t up to speed? Are there new system implementations or forms you are required to file by a particular compliance date? These will all need to be addressed, and a risk assessment can help identify and prioritize your tasks.
A new or amended regulation may require daily or weekly testing initially to ensure data integrity, effectiveness of disclosures, and adherence to procedures. Over time, as systems and training mature, the frequency of testing can be adjusted.
Breaking Down Compliance Activities
Segment Tasks for Focus
Breaking larger projects into smaller, well-defined tasks can be broken into smaller, more frequent items, spreading out the work throughout the year. For example, establish monthly examination topics, so that larger projects like email review or branch exams have the dedicated time and resources they need, and recurring tasks like reviewing state registrations are performed regularly. At the end of the year, check to ensure that all monthly reviews are still accurate.
Or, in the case of a new rule, testing might be conducted monthly in the first year to identify risks or gaps in processes. Over time, these tasks can consolidate into fewer, less frequent activities as confidence in your firm’s controls grows.
Incorporate Regulatory Deadlines
While breaking down tasks is crucial, firms must also account for hard fiscal year compliance deadlines, like those for filing form 13F or renewing registrations. Align your calendar with procedures to ensure specific requirements—such as scrubbing securities lists or uploading filings—are explicitly outlined.
Tailor Your Calendar to Your Business
Implement a Risk-Based Approach to Frequency
Your compliance calendar should reflect the unique risk profiles of your business. While regulatory calendars, like the FINRA calendar, outline key deadlines, firms must go beyond these to incorporate risk-based compliance activities. For example, a rule requiring an annual review may not specify when the review must occur, leaving firms to determine the appropriate frequency based on their risk assessments.
Adapt to Business Flows
Align your compliance calendar with your business cycle. For example, if your firm has peak activity in December and June, consider shifting non-urgent compliance tasks to less busy months. This strategic planning prevents bottlenecks and ensures resources are available when needed most.
Leveraging Technology for Efficiency
Move from Manual Tracking to Automation
As your firm grows, manual methods like spreadsheets and Word documents will become insufficient. Implementing automated compliance solutions Oyster Solutions can enable task delegation, progress tracking, and real-time visibility into pending activities.
Implement Collaboration and Shared Visibility
Leaders in your organization are concerned about risk and how risk impacts their organization. They need to know if there is a need to change. Usually, leaders really want to understand what is right, what they have to do to make their firm safer, what they need to do to make sure that when the firm is engaging clients, it is doing it well.
Collaborative tools ensure that all departments, from Compliance and Operations to Trading and Sales, are aware of their roles and deadlines. For instance, Operations might be tasked with gathering data, while Compliance reviews the results.
Building Flexibility into the Calendar
Plan for the Unexpected
Compliance is rarely straightforward. It is important to build time buffers into your calendar. Investigations, data discrepancies, or new regulatory developments can derail plans, so having extra time ensures firms can respond without undue stress.
Prioritize Tasks
Not all tasks are created equal. Conducting that risk assessment is the first and most important thing you can do to prioritize where you want your team to spend its time. On a more granular level, using prioritization techniques like color-coding (e.g., red for high-priority items, yellow for moderate, green for low) to differentiate between critical regulatory filings and aspirational testing can help your team adjust priorities in response to unforeseen challenges.
Continuous Improvement
Conduct an Annual Review and Implement Updates
Compliance calendars are living documents that must evolve with regulatory changes, business growth, and industry priorities. For investment advisors, conducting an annual review is required by SEC Rule 206(4)-7. As you conduct your review, ensure that you are updating your calendar to reflect new rules, changing deadlines, and regulatory focus areas. This ensures the calendar remains relevant and comprehensive.
Monitor and Delegate
Regularly reviewing your annual compliance calendar helps allocate your resources effectively. What were the findings during your testing? What were the recommendations and where are they implemented? What did you do in response to that? It’s a good time to go through and document, “We did this, this is what we found, this is how we dealt with it. This is how we plan on moving forward, and this is our focus for the foreseeable future on this particular topic.” Monitoring progress also identifies tasks that may require reassignment or additional oversight.
Delegating routine tasks frees compliance officers to focus on high-priority reviews and strategic initiatives. Delegating tasks can also identify who is best suited to special tackle tasks or projects. If your resources are limited, consider outsourcing routine tasks so that you can concentrate on higher priority items.
The Strategic Role of Compliance Calendars
A well-crafted compliance calendar is more than just a checklist—it’s a strategic tool for managing regulatory obligations, mitigating risks, and streamlining operations. Your compliance calendar bridges the gap between aspirational procedures and actionable tasks, ensuring that compliance becomes an integral part of business operations.
Tailor Your Calendar for Success
Every firm is unique, and so is its compliance calendar. Tailoring activities to fit the business model, regulatory environment, and risk profile is key. Whether it’s testing new controls, managing Form ADV updates, or filing quarterly reports, a customized approach ensures no detail is overlooked.
Plan for Growth
As your firm expands, your compliance needs become more complex. Collaborative tools and automated workflows can help scale calendars to accommodate larger teams and increased regulatory requirements. By investing in these solutions, firms position themselves for sustainable growth.
The Compliance Partner You Need
Oyster Consulting’s regulatory compliance consultants understand how to design and maintain practical and reasonable compliance programs. Our experts will conduct a deep dive into your firm’s policies and procedures to ensure your guides match actual business practices, and will provide reasonable solutions based on your unique business model.
Modern GRC Software to Grow With You
To protect your firm and your clients, your team needs modern GRC solutions. Oyster Solutions GRC software’s powerful integration and automation provide the surveillance tools your firm needs, accurate supervision and the reporting structure that regulators demand, all while giving your employees a streamlined, easy to follow experience.