Today, we offer our “Friday List,” an occasional feature summarizing a topic significant to investment management professionals interested in regulatory issues. Our Friday Lists are an expanded “Our Take” on a particular subject, offering our unique (and sometimes controversial) perspective on an industry topic.
Over the last several years, an increasing number of investment management firms have chosen to outsource the Chief Compliance Officer role and associated compliance function. In our experience, these firms make this decision for rational business reasons based on an assessment that outsourcing the compliance function is better than hiring a full-time employee. Usually, firms consider outsourcing because of an external event such as a less-than-perfect SEC exam or an institutional due diligence process that suggests unknown weaknesses. Some firms decide to outsource after yet another internal CCO changes jobs. Other times, firm management simply gets frustrated with the inherent limitations of the one internal compliance person. Regardless, we list below the top 10 reasons investment firms should outsource the CCO role and compliance function rather than hire an in-house employee.
10 Reasons Outsourcing Compliance Beats Hiring an In-House CCO
- Experience: A team of professionals can draw on decades of aggregate compliance experience to address a firm’s regulatory challenges.
- Knowledge: No one person can provide the depth of knowledge of several compliance professionals working collaboratively.
- Independence: A third party firm offers investors and other stakeholders an independent assessment of a firm’s compliance strengths and weaknesses.
- Industry best practices: A multi-person team working with multiple clients across the country has the industry vision to inform the compliance program.
- Accountability: A compliance firm stands behind its work and advice with a service level agreement and professional liability insurance.
- 24/7/365 support: A person may take PTO, but a team of professionals is available at all times for any emergency including unplanned client due diligence and SEC exams.
- Personal liability: Serving as CCO involves significant personal liability, which is better left to professionals that understand and accept the regulatory and career implications.
- Frees up internal resources: Internal personnel can focus on core activities such as portfolio management and fund-raising.
- Management: Senior managers can avoid the confusing and time-consuming process of hiring, retaining, and managing an internal CCO, only to start the process anew in the event the CCO leaves.
- Cost savings: Because of program efficiencies, outsourcing generally costs less than hiring a full-time employee.