I have a lot of respect for compliance professionals, Chief Compliance Officers, legal counsel and anyone in a regulated environment that is trying to keep their client out of trouble. At the same time, I occasionally am told stories involving compliance consultants that blow me away. So I decided to compile a list of signs that may signal you need a new compliance professional or a law firm to assist you with compliance.
- I drafted this report for you. It identifies every single deficiency that I uncovered. There are a lot of them and things don’t look so good for your firm. It is a roadmap for the Division of Examinations, FINRA, or a state securities regulator. I didn’t consider whether the contents of this report were privileged before sending it to you. Good luck!
- When you need to reach them for a compliance emergency, you can’t. They clock out at 4:30 or 5:00pm and aren’t prepared to help you or your business get it right after hours.
- They tell you what everyone else is doing, what you “need” to be doing; and they don’t tell you what the law actually says you must be doing.
- They defer to telling you “no”, because it makes their life easier.
- They aren’t able to provide you with a risk assessment to make informed business decisions.
- Hold on…that is a legal document. I can’t help you out with that. You are going to have to contact a lawyer.
- Hold on…that is a legal question. I can’t help you out with that. You are going to have to contact a lawyer.
- When asked about exploring a new, but related line of business, they tell you that they don’t have any experience with that area.
- They write poorly, but you need them to draft written responses to a deficiency letter.
- They gave you incorrect advice and it cost you time, money or energy to correct.