Signs You May Want to Reconsider Your Compliance Partner

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.

  1. 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!
  2. 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.
  3. 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.
  4. They defer to telling you “no”, because it makes their life easier.
  5. They aren’t able to provide you with a risk assessment to make informed business decisions.
  6. Hold on…that is a legal document. I can’t help you out with that. You are going to have to contact a lawyer.
  7. Hold on…that is a legal question. I can’t help you out with that. You are going to have to contact a lawyer.
  8. When asked about exploring a new, but related line of business, they tell you that they don’t have any experience with that area.
  9. They write poorly, but you need them to draft written responses to a deficiency letter.
  10. They gave you incorrect advice and it cost you time, money or energy to correct.

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