NSCP Currents: May 2017 Special Reprint

Managing the Impact of High CCO Turnover in Financial Services Sector

By Carlos Guillen

In 2016 when search firm Russell  Reynolds  released  its study of the role of the corporate compliance officer in the financial services sector(1), the most alarming finding was that there was a 40% turnover rate among CCOs  over a two-year period. This does not come  as a surprise to those of us in the compliance world.  We  have been dealing with  the  growing  impact  of  CCO turnover for some  time  as  asset  management  firms, banks and  insurance  companies  have  had  to  grapple with the increasing complexity of compliance regulation and  the  dearth  of  qualified CCOs. Read the full article here.

The Morning Risk Report: Compliance Services Firm Form Council to Promote Best Practices

Four compliance services are banding together with a compliance software company and a cybersecurity firm to form an advisory council to promote best practices among compliance industry consultants. The BasisCode Advisory Council will provide independent guidance and industry insights that reflect ongoing changes in the regulatory environment, incorporate feedback from member firms’ clients and offer a way for companies to tap into the expertise of more consultant firms without having to have different technology platforms for each one… read the entire WSJ article

Leading Compliance Consulting Firms Join BasisCode Advisory Council

5 Leading Compliance Consulting Firms Join BasisCode Advisory Council as charter members

ATLANTA, January 3, 2017 – BasisCode Compliance LLC (www.basiscode.com), a leading provider of regulatory compliance software solutions, has formed an advisory council of leading compliance consulting firms to provide industry input in the continuing development of its award-winning compliance software platform.

The BasisCode Advisory Council consists of four prominent compliance consulting firms – Alaric Compliance Services, Cipperman Compliance Services, Hardin Compliance Consulting, and SEC Compliance Consultants – as well as a leading cyber security specialist – BW Cyber Services. The addition of cyber security expertise to the council signals the growing importance of incorporating cyber security into next generation solutions.

The advisory council will provide independent guidance and industry insights that reflect ongoing changes in the regulatory environment and the members’ client feedback. The council’s input is designed to ensure the Compliance Consultant Manager continues to serve the evolving needs of industry consultants and their clients allowing them to focus on their core offerings.

“Simply put, the BasisCode Advisory Council will help us better serve our consulting clients and their clients,” said Carlos Guillen, BasisCode Compliance president and CEO.  “By incorporating the group’s expertise into our platform, we hope to ensure that all compliance and regulatory consultants have the tools they need to do their job more effectively.”

“We bring to the Council our unique position as a longstanding CCO outsourcing leader whose consultants have accumulated decades of hands-on experience and insight,” said Alaric Compliance Services CEO Guy Talarico.  “Complementing our expertise with time-tested technology is ultimately a win for our clients, who can reduce their reliance on manual processes without us having to build capabilities from scratch.”

“In the end, it’s all about making it easier for the industry to manage an effective compliance program,” said Todd Cipperman, Cipperman Compliance Services. “By participating in the BasisCode Advisory Council, we can share best practices and experiences that will ensure that our clients are prepared to handle changing regulatory challenges.”

“By reducing the use of spreadsheets, email, paper and partial solutions, our clients know that we are providing our services in the most efficient, secure, and cost-effective manner,” said Jaqueline M. Hummel, Hardin Compliance Consulting. “The goal is to determine what our clients need and applying modern technology to provide an optimal solution to managing compliance programs. Working with a cyber-security expert will help us address one of the highest – and least understood – risks facing the industry.”

“While technology itself will never replace the expertise and judgement provided by a compliance consultant, technology is absolutely required in order to provide an effective and scalable compliance offering to clients” said John Lukan, of SEC Compliance Consultants, Inc.  “While we explored building our own proprietary technology, we realized that an enterprise solution requires specific expertise that is difficult and expensive to create and maintain, especially in light of the ongoing business continuity and security requirements. After extensive research, we found BasisCode offered the flexibility and enhanced functionality we were seeking.  We are excited to be part of this new advisory group and able to contribute to its future development.”

Michael Brice, founder and CEO of BW Cyber Services said, “By participating in the BasisCode Advisory Council, we can share cyber best practices and industry experiences that will ensure that clients are best prepared to handle changing regulatory challenges in a pragmatic manner that also provide real-world, operational benefits.”

Initial members of the forum will serve 18 to 24 months.

About BasisCode

BasisCode Compliance LLC (www.basiscode.com), headquartered in Atlanta and founded in 2011, is a leading provider of regulatory compliance software solutions which help manage the risk lifecycle from identification to resolution. From core compliance to personal trading and insider trading, each BasisCode software solution is available as a stand-alone product or offered as part of an integrated package.  The company’s hallmark, audit-ready capability is available in all BasisCode solutions and helps firms maintain a culture of compliance.


About Alaric Compliance Services

With more than 275 years of cumulative financial services experience, we have completed more than 100 exams as CCOs, and 500+ reviews and exams as regulators and advisors.  Our seasoned consultants bring a fresh perspective, time-tested technologies and an unsurpassed wealth of CCO experience to help clients anticipate and mitigate a range of regulatory, compliance and cyber-security risks.  With offices in New York and Boston and a diversified client base spanning start-ups to mature businesses with more than $160 billion in assets under management, we have been meeting our clients’ compliance needs since 2004.  For more information, visit www.alariccompliance.com.

About Cipperman Compliance Services

CCS helps registered funds and money managers create a culture of compliance.  CCS leverages the experience of a multi-disciplinary team and takes full accountability for its advice and services. For more information, visit www.cipperman.com.

About Hardin Compliance

Hardin Compliance Consulting is a full-service compliance consulting firm, offering expert regulatory compliance services and solutions to investment advisers, broker-dealers, private funds and investment companies. HCC has the relevant experience to help clients build and maintain quality personalized compliance programs based on strong processes and a culture of compliance. For more information about Hardin Compliance, visit www.hardincompliance.com.

About SEC Compliance Consultants

Since 2003, our team has been providing expert compliance consulting services to the financial services industry.  With broad experiences and skill-sets, our consultants quickly gain a deep understanding of a client’s business, workflows, and control environment, which allows us to help clients manage and mitigate compliance risk and conflicts of interest.   Our client base includes some of the most respected names in the financial services industry and ranges from large international firms to small firms with only a few key people. Our satisfied clients include advisers, institutional investors, directors, private fund advisers, investment companies, and broker-dealers. Our service offering includes compliance consulting, mock regulatory exams, expert witness services and selective, outsourced CCO services. For more information, visit www.seccc.com.

About BW Cyber Services

At BW Cyber Services, our goal is to help our clients quickly become cyber compliant, cyber knowledgeable, and cyber protected.  In this technologically complex world, criminals, nation states, “hacktivists”, and even tech savvy adolescents are continuously searching for weaknesses or vulnerabilities that will enable them to prey upon your business.  To help mitigate these risks of attack and address your cyber compliance needs, BW Cyber Services provides turn-key cyber audit and cyber regulatory compliance services tailored to meet both the compliance and real-world security needs of our clients – which include NFA and SEC registrants, as well as family offices.  Our consultants are not only cyber experts – they also possess decades of hands-on financial industry expertise.  It is this expertise that allows us to provide reasonably priced, pragmatic solutions that will benefit your business well beyond technology implementation or administrative compliance. For more information, visit www.bwcyberservices.com.

Cipperman Compliance Services Implements BasisCode Compliance Software Platform

WAYNE, Pa and ATLANTA, November 15, 2016 – Cipperman Compliance Services LLC (www.cipperman.com), a leading provider of regulatory compliance services for investment advisers, registered and private funds, broker-dealers and money managers that collectively manage more than $40 billion in assets, is implementing BasisCode Compliance LLC’s software platform to improve compliance management for its global clients.

BasisCode Compliance is the industry’s most comprehensive software that improves compliance management for financial firms, compliance consultants, law firms and other service providers.  The software simplifies and centralizes compliance management, ranging from compliance testing and risk assessment to trading surveillance, insider trading and staff certifications. The rules-based engine makes it easy for users to modify workflow logic throughout the compliance management lifecycle.

“In the financial services and investment management industries, building a culture of compliance requires the implementation of effective compliance technologies by the best compliance professionals who can assess, interpret and react to the data,” said Todd Cipperman, founding principal of Cipperman Compliance.  “Our decision to partner with BasisCode as the best-of-breed compliance management software will ensure better regulatory outcomes and allow our expert team of compliance professionals to focus their time and effort on making judgments and providing advice to our rapidly expanding client base.”

Compliance officers face greater scrutiny than ever, with regulators naming and prosecuting them for not only malfeasance but increasingly for negligence as well.  Compliance outsourcing has become commonplace as regulatory pressures compel registrants to improve compliance processes and procedures to reduce firm and client risk.  Additionally, regulators have indicated that they might require third-party compliance reviews of regulated entities within the coming year.

With registrants facing this combination of pressures, outsourced providers like Cipperman Compliance are working to quickly scale their infrastructures to support greater processing volumes effectively and efficiently.

BasisCode Compliance centralizes the industry’s broadest range of functionality within a single platform, increasing compliance management processing visibility.  The BasisCode Dashboard displays a consolidated inventory of a firm’s program while the BasisCode Portal engages consultants, supervisors as well as non-supervisory staff in maintaining a culture of compliance.

“Our innovative cloud-based platform, and our latest Insider Trading ManagerTM software, gives registrants and consultants more powerful tools to reduce compliance risk while enhancing the quality of their compliance programs,” said BasisCode Compliance President and CEO Carlos Guillen.  “This partnership with Cipperman Compliance also validates our leadership as the industry’s most extensive, integrated and advanced compliance management software available.”

About Cipperman Compliance Services LLC

Cipperman Compliance Services is a leading provider of holistic third party compliance services to the investment management industry.  CCS is one of the industry’s leading providers of regulatory compliance services for both registered advisers and funds. CSS offers a variety of services, including providing a designated CCO with support staff and program management, for a full range of clients who, combined, manage more than $40 billion in assets. CCS provides the expertise that ensures a quality overall compliance experience.  Given the visibility of regulatory oversight in today’s environment, Cipperman’s position as an independent partner is extremely valuable to fund sponsors and investment managers.  For more information, visit www.cipperman.com.


About BasisCode

BasisCode Compliance LLC (www.basiscode.com), headquartered in Atlanta and founded in 2011, is a leading provider of regulatory compliance software solutions which help manage the risk lifecycle from identification to resolution. From core compliance to personal trading and insider trading, each BasisCode software solution is available as a stand-alone product or offered as part of an integrated package.  The company’s hallmark, audit-ready capability is available in all BasisCode solutions and helps firms maintain a culture of compliance.

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Insider Trading Manager and BasisCode Compliance are trademarks of BasisCode Compliance LLC. All other tradenames are the property of their respective owners.


New SEC Rules Increase Scrutiny of Outside Compliance Chiefs

The new SEC rules underscore the importance of selecting a qualified chief compliance officer.

By Carlos Guillen

With the Securities and Exchange Commission announcing adoption of Form ADV amendments proposed last year, regulated entities must now report if they outsource their chief compliance officer, and specify the name and tax identification for that individual.

The goal, according to the agency, is to enhance monitoring and regulation of the asset management industry, and improve the agency’s ability to assess potential risk. Firms must file newly amended Form ADVs under the requirement with the first amendment filed after October 1, 2017.

Explaining the rule, the commission noted its staff “has observed a wide spectrum of both quality and effectiveness of outsourced chief compliance officers and firms.” Advisors are already required to report on their Form ADV the names and addresses of independent public accountants that perform audits, surprise examinations and internal control reviews. The broadened amendment underscores the importance to regulators of ensuring the quality of a firm’s third party service providers.

Read the entire article published originally on Wealth Management .com at   http://www.wealthmanagement.com/regulation-compliance/new-sec-rules-increase-scrutiny-outside-compliance-chiefs ]


Carlos Guillen is the president, CEO and founder of BasisCode Compliance.

BasisCode Launches First Comprehensive Insider Trading Software Solution

Insider Trading Manager Detects Suspicious Trades by Tracking and
Analyzing Trading through Pre-Programmed Filters;

Integrates into Compliance Work Flow and Minimizes “False Positives”

ATLANTA, October 11, 2016 – The first comprehensive insider trading software, which tracks and analyzes trading in real-time and detects suspicious trades, has been introduced by BasisCode Compliance LLC (www.basiscode.com), a leading provider of regulatory compliance software solutions.

Insider Trading Manager™ addresses a major and prevalent risk faced by financial services firms today in terms of reputational damage and even survival. The software provides a complete work flow analysis totally integrated into a firm’s compliance monitoring system.

“Unlike the limited number of insider trading modules available today which are all event-driven and generate huge numbers of false positives,” said Carlos Guillen, president and chief executive officer, BasisCode, “Insider Trading Manager is not only a more effective monitoring system but also provides a set of productivity tools that vastly improves the efficiency and productivity of insider trading surveillance.”

As an integral part of a firm’s compliance monitoring system, Insider Trading Manager monitors all of a firm’s trading activity – for its clients and its employees’ accounts. Monitoring is conducted on an ongoing basis and is not activated solely on the basis of a material event.

The software enables firms to detect the misuse of material non-public information by identifying potentially illegal transactions using patent-pending filtering mechanisms designed to reduce the probability of false positives and enhance the accuracy of items that warrant review and includes a complete workflow and audit trail. The process saves time, reduces risk and provides for more meaningful analysis that can be applied to both firm and employee transactions. The improved efficiency allows users to expand their oversight to a broader range of activities while providing increased risk management assurance.

“Insider Trading Manager is a vast improvement over the insider trading surveillance systems in use today which review pre- and post-event trading records only after a key event takes place,” said Guillen. “This requires an enormous effort in time and financial resources to sift through thousands of trading records to identify what we call ‘one needle in a haystack.’ With Insider Trading Manager, an investigation or review is triggered only when suspicious trading is detected by the system’s ongoing monitoring of trading, and then a news search is initiated to determine whether there is any connection. The time and paperwork savings that result from the software are at least equal to the cost of one or two (or more) full-time employees equivalent.”
Prospective users of Insider Trading Manager include financial services and investment management firms, publicly-traded companies, law and accounting firms, boards of directors and consulting firms. The cloud-based software solution is available on a standalone basis or as part of an integrated suite where it can be used in combination with the BasisCode ComplianceTM and/or BasisCode Personal Trade Manager, both part of the company’s compliance suite of products.

BasisCode’s management team has decades of technology, financial and compliance expertise in designing, developing and managing enterprise compliance systems for a broad spectrum of organizations, from small asset managers to large institutional investors.
Insider Trading Manager will be shown for the first time at the upcoming National Society of Compliance Professionals (NSCP) National Conference in Washington, D.C. being held at the Omni Shoreham Hotel from October 17 to 19, 2016. BasisCode will be providing demonstrations at table #6. For more information about Insider Trading Manager, contact or call sales at 678-819-1991 extension 104.

About BasisCode

BasisCode Compliance LLC (www.basiscode.com), headquartered in Atlanta and founded in 2011, is a leading provider of regulatory compliance software solutions which help manage the risk lifecycle from identification to resolution. From core compliance to personal trading and insider trading, each BasisCode software solution is available as a stand-alone product or offered as part of an integrated package. The company’s hallmark, audit-ready capability is available in all BasisCode solutions and helps firms maintain a culture of compliance.

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Insider Trading Manager and BasisCode Compliance are trademarks of BasisCode Compliance LLC. All other tradenames are the property of their respective owners.

Software to Play Increasingly Important Role Given Scarcity of Skilled Compliance Specialists


At the end of a year in which regulators placed compliance management at the top of their list of priorities, financial firms should assess the processes and systems they have in place to prevent compliance breaches, such as failing to develop and enforce written policies and procedures (P&Ps). According to “Cost Of Compliance 2016,” a Thomson Reuters global survey of financial services firms, technology solutions may play an increasingly important role given the scarcity of skilled compliance talent.

[This article is published in full at Corporate Compliance Insights.  The Thomson Reuters Cost of Compliance survey findings can be found at: https://risk.thomsonreuters.com/special-report/cost-compliance-2016.]

Tech Prep Ahead of a Compliance Review



By Carlos Guillen, President & CEO BasisCode Compliance

When Securities and Exchange Commission Chair Mary Jo White testified before the U.S. Senate Committee on Banking last month, she reiterated her recommendation that the SEC propose a new rule requiring independent compliance reviews of registered investment advisers.  The goal isn’t to replace regulatory exams but to improve overall compliance among what she described as the “vast and growing” population of RIAs.

[Originally published at Financial Planning and Bank Investment Consultant]

BasisCode Compliance named WealthManagement.com 2016 Industry Awards finalist

Atlanta, Ga. – July 19, 2016 – BasisCode Compliance, provider of the industry’s most comprehensive integrated compliance management software solutions for investment advisors, broker/dealers, compliance consultants and other professional services firms, has been named a finalist in the compliance category of WealthManagement.com’s 2016 Industry Awards for the version of its software developed for compliance consultants.


How software can help smooth the transition to fiduciary-rule compliance

By Carlos Guillen, President & CEO BasisCode Compliance

investment_newsAlthough the U.S. Department of Labor’s (DOL) fiduciary rule has become the subject of two new lawsuits that could delay implementation, many investment advisers, brokers-dealers and other firms that offer retirement accounts are making operational changes to transition from transactional commission structures to fee-based fiduciary relationships.  [Originally published at Investment News]

Chief compliance officer held personally accountable

By Carlos Guillen, President & CEO BasisCode Compliance


It seems not a day passes without an enforcement action related to a compliance breakdown of some sort grabbing headlines.   Precedent is being set to suggest that a firm’s senior executives, including the chief compliance officer (CCO), could be held personally accountable for inadequate compliance oversight.

[Originally published at Money Management Executive]

Software to make compliance easy for financial advisers

 By Sheryl Rowling


Following through and documenting ongoing compliance tasks can sometimes be overwhelming. Yet, this is a reality all financial advisers must face. From returns dispersion to reporting, billing to fee schedules, advertising to gift recording, model compliance to ongoing management documentation, and monthly employee activity reports to annual compliance reviews, there is a never-ending stream of activities to perform and records to keep.   Two software providers have addressed this need: BasisCode Compliance and RIA in a Box.

[Originally published at Investment News]

HA&W Wealth Management Turns to BasisCode for Compliance

By Anthony Malakian, US Editor of Waters magazine and WatersTechnology.com

waters_technologyBasisCode Compliance, which launched a self-subscription service this week, is helping HA&W Wealth Management to more efficiently manage its compliance needs.   HA&W Wealth Management’s Debbie Powell talks to Waters to explain how the firm is using BasisCode Compliance, while BasisCode Compliance’s Carlos Guillen discusses the vendor’s new self-subscription service and its soon-to-be-launched insider trading software for detection.  [Originally published at Waters Technology]

Do Yourself a Favor: DON’T Do Yourself A Favor (Compliance Tech Tip for Improving Business Expense Management)

By Carlos Guillen, President & CEO BasisCode Compliance


In an effort to influence prospects or clients, corporate executives occasionally blur the lines between acceptable forms of persuasion and expense management misconduct.  If there’s any message executives and compliance supervisors should communicate before employees turn above-board business into bribery, it’s: Do yourself a favor, and don’t do yourself a favor when wooing business.

Compliance Consultants Turning to Technology While in Regulators’ Crosshairs

The rise of high-profile regulatory mishaps involving compliance gatekeepers is leading to greater scrutiny of technology tools


By Carlos Guillen, President & CEO BasisCode Compliance

With compliance management intermediaries in regulators’ crosshairs, some law firms and consultants are turning to technology to improve compliance management on behalf of their clients while running their businesses more effectively. In February, for instance, Warrendale, Pennsylvania-based Hardin Compliance implemented a new software platform to standardize and streamline compliance management for its clients.

[Originally Published at LegalTech News]

Hardin Compliance Consulting selects BasisCode Compliance software

ATLANTA, Ga. – BasisCode Compliance today announced that Hardin Compliance is implementing the BasisCode Compliance™ software to help the full-service regulatory compliance consulting firm more easily manage compliance on behalf of its clients.

BasisCode introduced its new software platform, designed specifically for compliance consultants, law firms, auditors, accountants, fund administrators and other compliance management intermediaries, in October.  BasisCode Compliance is the industry’s broadest set of integrated software solutions that improve compliance management for consultants, asset managers, investment advisors, broker/dealers, insurance companies and other service providers.

“Previously, like many consultants, we relied on manual processes and spreadsheets, but we have found the BasisCode Compliance software does a better job helping us aggregate and manage compliance data across our varied clients,” said Hardin Compliance Managing Director Jaqueline Hummel.  “Now our staff can be more productive and we can document compliance management activities in a more structured way, for internal and external reporting.”


Compliance Software in the Spotlight with Consultants in Regulators’ Crosshairs

By Carlos Guillen, CEO and President, BasisCode Compliance

Consultants Compliance Software with Wealth Management

Fueled by an increasingly risk-averse regulatory environment, the compliance consulting industry has grown sharply in recent years.  A number of consultants are turning to technology to quickly put a more scalable infrastructure in place and to better manage compliance programs on their clients’ behalf.

With consultants looking for ways to manage growth and increased operational demands, compliance software is expected to gain much greater global adoption in the next few years.  According to research firm MarketsandMarkets, the global market for GRC solutions is forecast to double from $15.98 billion USD in 2015 to $31.77 billion USD in 2020, with North America seeing the strongest growth.[1]

But for now, most consultants continue to employ error-prone and inefficient manual methodologies for managing their clients’ compliance programs.  “Previously, like many compliance consultants, we relied on manual processes and spreadsheets,” said Hardin Compliance Managing Director Jaqueline Hummel.  “By automating compliance management, we can now aggregate and manage compliance data across our client base consistently, help team members collaborate more effectively, create an audit trail of who does what when, and minimize disruption should team members change.”

The ability for consultants to effectively manage compliance, particularly across a diverse client base, is a challenge regulators acknowledge.  In November, the Securities and Exchange Commission (SEC) issued a risk alert based on recent examinations of investment advisers and funds that outsource their chief compliance officers.  SEC staff conducted nearly 20 examinations of firms with outsourced CCOs, and found their effectiveness depended on frequent communication with advisory personnel, devoting sufficient time and resources to performing their compliance duties, and receiving unfettered access to client records.

Conversely, outsourced CCOs who “infrequently” visited their clients’ offices and conducted “only limited reviews of documents or training on compliance-related matters while onsite” generally were less effective in implementing a robust compliance program. As this SEC alert suggests, compliance gatekeepers may increasingly find themselves in regulators’ crosshairs, and will be held accountable for failing to uphold professional standards by ignoring compliance red flags.

In December, the SEC suspended five accountants and two audit firms after violating several compliance-related rules. SEC Director of the Division of Enforcement Andrew Ceresney said gatekeepers “… must be held responsible when systemic failures such as inadequate engagement procedures, staffing or supervision cause the firm’s work to fall significantly short of expected standards.”

Nevertheless, regulators often recommend outside consultants as a useful resource for helping firms manage their compliance programs or respond to a regulatory inquiry or deficiency.  In a recent case against The Robare Group, a Houston-based investment advisor, judge James E. Grimes concluded that “employing a compliance professional and following his or her advice” met industry standards of due care.[2]

The SEC alleged that the firm failed to provide adequate disclosure in its Form ADV, recommending mutual funds to clients without disclosing a conflict of interest.  Charges were dismissed in part because the judge found that even experienced compliance professionals find it difficult to appropriately disclose conflicts of interest.  The firm’s principals conceded they did not have expertise in this area, and instead engaged experts to help draft their Form ADV.  The judge acknowledged the difficulty in meeting the disclosure requirements, and credited the firm’s principals for seeking outside expertise.

Since enacting the so-called Compliance Rule (Rule 206(4)-7 of the Advisers Act) in 2004, the SEC has become increasingly aggressive in bringing enforcement actions against advisers for failure to comply.  In 2014 alone, the SEC brought more than a dozen cases for failure to comply with the Rule, and 2015 saw at least as many cases.  The uptick in settlement orders alleging violations of the Rule indicates the SEC’s willingness to punish advisers for being negligent in establishing what the Commission views as appropriate internal controls and procedures.

Defendants in many cases that come to light are required to hire an independent compliance consultant (“ICC”) that is “acceptable” to the regulatory body involved in the case.  Among the criterion regulators use in determining the abilities of an ICC are its independence, its expertise and its resources.

Against this backdrop, the compliance consulting industry has seen dramatic growth in recent years.  Many clients engage consultants for expert ad hoc support; while others hire consultants to serve as their CCO.  Some consultants are brought in as a defensive measure after a breach has occurred or in reaction to a regulatory inquiry, deficiency letter or remedial sanction.

On the other hand, many financial firms use consultants to help them manage compliance proactively, for instance, to help them register for the first time in their state, or to help them transition between state and federal registration.  Additionally, firms use consultants to supplement their staff to perform tasks such as testing and monitoring of policies and procedures, making regulatory filings, performing advertising reviews, updating required documents and procedures, conducting mock audits, preparing annual reviews and evaluating the firm’s cyber-security program.

Relatively new to the compliance consulting space is a new breed of technology tools that enable consultants to help their clients implement and maintain compliance controls; manage risk consistently across their client base; and thereby run their practices more effectively.

These more advanced software tools deliver an enterprise view of compliance tasks, such as testing, staff certifications and risk assessments, to help consultants manage their clients’ compliance programs more easily and effectively.  Some feature a dynamic dashboard that allows consultants to instantly toggle between client views; and a secure online portal, with centralized activity management.  Automated reminders can be routed and time-stamped to serve as an audit trail of actions taken, when and by whom.

The software helps consultants (1) standardize the documentation of testing a firm’s policies and procedures; (2) produce reports evidencing their reviews quickly and easily; and (3) prioritize their work with automated reminders of upcoming tests and regulatory deadlines.   It also allows consulting firms to view the status across their clients’ compliance programs using a customizable dashboard.

Hardin has changed its service model over the last three years to a team-based approach to provide better coverage for its clients.  If one consultant is unavailable, another can immediately step in.  Hardin’s new team-based model led the firm to seek an integrated software solution to facilitate data centralization, workflow collaboration and process consistency.  Through automation, the firm can now share rich historical insight with customizable audit-ready reports whenever a team member, client or regulator requests it.

Particularly when it comes to the sensitive duty of managing compliance, consultants are facing increased regulatory scrutiny.  The question of where they house client data may eventually be held to the same professional standards, such as SSAE 16,[3] that other service providers must meet.  Expertise in application development, business continuity and security standards falls outside of most compliance consultant’s core capabilities.  Consultants face significant unintended risks when attempting to develop and manage software internally, including poor source code management, quality control and infrastructure support.

Hardin found very few options when it came to their unique automation requirements as a compliance consultant.  Said Hummel: “Relying on software developed by specialists in this space was a faster, easier and less risky way for us to scale capacity to handle multiple compliance programs while keeping our focus on what we do best.”

Retention of a lawyer, auditor, compliance consultant or any other third party provider equipped with the latest software will not absolve a firm should a deficiency arise.  But technology tools enable consultants to play better defense by identifying problems before they metastasize. They put compliance gatekeepers in a better offensive position, showing regulators they are actively invested in safeguarding clients.  Moreover, they put consultants in stronger position vis-à-vis competitors as financial firms make proactive compliance management a higher priority by using the best technology-enhanced tools the market has to offer.

[Originally Published at WealthManagement.com]

For more information on how consultants and hedge funds can manage their compliance, read more about the Compliance Consultant Manager.

Voices: Being Ready When Regulators Come



By Carlos Guillen, President & CEO BasisCode Compliance

Upgrading technology is the secret to staying in good stead with regulators.

By streamlining risk assessments, compliance reviews and ongoing compliance management, technology can help financial firms and compliance consultants maintain a culture of compliance, which regulators are making a top priority this year.

Technology can play an even more important role in reaction to a breach, delivering hard evidence of a company’s efforts to maintain an audit-ready business. Here’s how:

  1. Proactively identify, mitigate and manage compliance risk
  2. Actively maintain and document P&Ps
  3. Maintain fluid communication between employees and supervisory staff

[Originally Published at Financial Planning]

BasisCode is Hiring a Developer

BasisCode Compliance is hiring an experienced web developer. Must be highly proficient in HTML, CSS, JavaScript, and jQuery. Experience with ASP.Net is also required along with related technologies such as C#, Entity Framework, Web API, MVC, Web Forms, and IIS. Expertise within Visual Studio is expected. Experience with Telerik and Kendo UI is highly preferable. Hybrid mobile experience is also preferable.

Must be easy to work with and self-driven. No micromanagement here. We need people who will work remotely, independently and meet assigned deadlines with high quality output as expected by our clients.  Work for a small, growing company with competitive benefits and compensation structure. If interested, please send a resume and any other relevant information to .

When it Comes to Compliance, Compliance Evidence is Everything

As industry debate intensifies regarding chief compliance officer liability and the perils of outsourcing, compliance professionals should take a closer look at how technology can keep their firms in good stead with regulators.  When it comes to compliance management and malfeasance, compliance evidence is everything, and technology can prove invaluable.  Regulated firms and those that rely on consultants, third-party administrators, law firms or others to handle compliance can reduce the risk of lapses by leveraging software solutions designed to better manage compliance programs.

To see a complete list of everything included and many more ways to save you time, visit the “Solutions Overview” page. Also, check out the video for a quick glimpse into BasisCode.

Compliance Evidence

By Carlos Guillen, President & CEO BasisCode Compliance (Originally published at Financial Planning)

Some examples of evidence include: testing and certifications, risk assessment, gifts and entertainment, whistleblower, personal trading, insider trading monitoring, automated workflows, reminders, alerts, forms studio, documents portal, extensive reporting and an employee portal. By using BasisCode compliance software, you are able to track and automate many aspects in one place from home or on your mobile app. This is your solution to managing all of compliance in one place. You will not have to piece together many solutions to get results.

About BasisCode Compliance

BasisCode Compliance offers the industry’s broadest set of integrated compliance management software that improves compliance management for asset managers, investment advisors, broker-dealers, compliance consultants, law firms and other professional service providers.  BasisCode Compliance was named a finalist in the compliance technology category of WealthManagement.com’s 2015 Industry Awards, which honors outstanding achievements by companies that help advisors better manage their businesses through innovation.  The intuitive BasisCode Compliance software spans functionality, from testing and risk assessment to personal trading and certifications, compliance evidence, enhancing compliance controls and decision-making for financial services firms and their clients.

Managing the convergence of compliance and technology

October 15, 2016

By Carlos Guillen, President & CEO BasisCode Compliance

investment-newsCitigroup recently agreed to pay a $15 million penalty for failing to enforce compliance breaches that technology could have prevented. As evidenced by such high-profile cases, even some of the leading financial firms overlook the role that technology can play in avoiding costly compliance failures.

[Originally Published at Investment News]

Is Compliance Keeping Up With Your Automated Advisory Tools?

By Carlos Guillen, President & CEO BasisCode Compliance

Automated advisory tools such as account aggregation, portfolio analysis and financial planning systems are being touted for their ability to increase productivity while allowing advisors to collaborate more easily with clients.  Included in many next generation toolkits, robo advisors rely on algorithms and model portfolios to automatically align client portfolios with risk tolerance and other predefined thresholds.

[Originally Published at Financial Planning]

BasisCode Compliance introduces new software for compliance consultants

Atlanta, GA. – October 27, 2015 – BasisCode Compliance today announced a new version of its software developed specifically for compliance consultants.  BasisCode Compliance is the industry’s broadest integrated compliance software platform for asset managers, advisors and other financial services firm.   The new software helps attorneys, auditors, fund administrators, accountants and other consultants more easily manage compliance on behalf of their clients. (more…)

Compliance Data Analytics: Do as Regulators Say AND as They Do

By Carlos Guillen, President & CEO BasisCode Compliance


When it comes to leveraging technology to create and manage an effective compliance program, investment advisors should take a page from regulators’ rule books.  The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) announced that one of its top three priorities for the year, along with protecting retail investors and assessing market-wide risks, is using data analytics to identify signs of illegal trading activities, conflicts of interest or other forms of misconduct.

[Originally Published at ThinkAdvisor.com]

BasisCode Compliance named WealthManagement.com 2015 Industry Awards finalist

wma15-brand-mainBasisCode Compliance, provider of the industry’s broadest integrated compliance software for asset managers, advisors and other financial services firms, has been named a finalist in the compliance technology category of WealthManagement.com’s 2015 Industry Awards, the first program to honor outstanding achievements by companies that help advisors better manage their businesses through innovation, enhanced service quality or an enriched advisor/client experience. (more…)

BasisCode Compliance, SEI and Other Expert Panelists Address Compliance Concerns Facing Investment Managers

A panel of experts from SEI, BasisCode Compliance, and EisnerAmper discussed best practices, technology and data management, and compliance controls at a knowledge partner event hosted by SEI on April 23. The panelists shared their experiences, practical guidance and insights to address some of the concerns managers have as they reconcile their compliance programs against their business needs.

SEI Selects BasisCode Compliance Technology Platform for Managing Compliance Across Products and Jurisdictions

OAKS, Pa., April 13, 2015 – SEI (NASDAQ:SEIC) today introduced SEI Firm Compliance, a new global regulatory management framework that equips investment organizations to oversee and orchestrate compliance functions firm-wide, across investment products and regulatory jurisdictions. SEI’s Investment Manager Services (IMS) division developed the compliance framework as an add-on to the customized global operating platform it provides to its investment manager clients. (more…)

With Fiduciary Rules Pending, Get Your Compliance Act in Order

By Carlos Guillen, President & CEO BasisCode Compliance

Financial Planning

Given the graying of America, advisors must implement operational best practices to compete for and manage increasingly lucrative retirement account dollars.  As investors struggle to digest retirement plan language that can obscure fee-sharing arrangements, which ultimately affect the performance of their IRA and 401(k) accounts, both the SEC and Department of Labor are mulling historic regulatory reforms.

[Originally Published at Financial Planning]