Speech by SEC Staff:
Welcome and Closing Remarks
CCOutreach National Seminar

by

Lori A. Richards

Director, Office of Compliance Inspections and Examinations
U.S. Securities and Exchange Commission

Washington, DC
November 14, 2006

Good Morning. I'm Lori Richards, Director of the SEC's Office of Compliance Inspections and Examinations. Along with Buddy, I'm pleased to welcome you to the SEC today, and to the Second CCOutreach National seminar for investment adviser and investment company chief compliance officers.

This CCOutreach program is designed to provide a forum to discuss compliance issues in a practical way, to share experiences, and to learn about effective compliance practices. It's sponsored by both the Commission's Division of Investment Management and the Office of Compliance Inspections - and this reflects the philosophy of the program - we mean to marry the legal requirements of the securities laws and rules with their practical application in compliance programs. We know well that advisers and funds are widely diverse in size and type, and that compliance programs are too. Indeed, while compliance with the law is a minimum standard, the compliance process by which firms achieve that standard is not a one-size-fits-all proposition. This makes it critical for all of us to have a forum to discuss various mechanisms that work in real-life settings.

Today's National Seminar caps off a series of regional CCOutreach seminars that we held across the country this summer. In total, examiners in our field offices held 27 regional seminars with CCOs in their regions to discuss compliance issues of concern. Almost 2,000 chief compliance officers attended the regional seminars. The regional seminars ranged in size from 30 to about 120 attendees, and were purposefully smaller in size to allow for interaction among the participants.

Our goal was to make these regional sessions relevant and helpful to CCOs of all types and sizes. In the seminars, the participants together worked through various compliance risk scenarios, and as a group, identified compliance risks and compliance policies and procedures that could address those risks. The scenarios dealt both with some fairly straightforward compliance risks that exist in small shops, as well some that were quite complicated based on the compliance complexities inherent in a large and diversified asset management firm.

How did the regional seminars go? We heard from most attendees at the seminars that they found them valuable -- indeed over 95% of those attending rated them in comment cards as "excellent" or "good." Most participants praised the relevancy of the topics, the speakers, and the materials used. And of course, most liked the cost - they were free! Another comment often made by participants was that they really liked having the opportunity to interact informally with SEC examiners - I suppose that the seminars removed some of the mystery or the anxiety that comes from dealing with any auditor. And, we're probably much less scary when we're not conducting examinations! On behalf of the exam staff, we too valued the regional seminars and enjoyed meeting with local compliance staff and talking informally about compliance issues.

I'll have a little bit more to say about the regional seminars for 2007 at the end of today's conference.

Ultimately, in the CCOutreach program, we hope that by providing a forum to discuss practical compliance issues, you will use what you learn to strengthen your firms' compliance programs. But there are also a couple of intangible benefits to CCOutreach that are worth mentioning -

• One intangible is the dialogue and communication between SEC staff and industry compliance professionals -- outside of the examination process. We're seeing benefits from the improved communication - and we want to continue to foster this communication - better communication helps us to understand the industry and your issues better, and it helps you to understand us, our regulations and our process better.
   
• Another important intangible of the CCOutreach program -- it should demonstrate to you and to the firms that employ you -- we stand squarely behind compliance officers and your mission. You are key to the success of our mission to protect investors, and we value and respect the work that you do. We want you to have the tools, resources and support that you need to do it.

Chairman Cox is out of the country and could not be with us in person today, to express his strong support for your work and for the CCOutreach program, he sends his welcome to you via videotape. (run tape)

A couple of words about what we ask of you today -

First, we ask that you use the blue cards provided for questions - write your questions about the topic under discussion on a card and give the card to one of the SEC staff in the auditorium. You don't need to put your name on the card. The moderator for each panel will try to raise questions from the audience for the panel to respond to if time allows.

Second, we want your feedback about this conference - please complete the questionnaire about the conference and provide it to an SEC staff person at the door at the end of the day today.

On behalf of all the SEC staff who have worked on the CCOutreach Program, we hope that you find today's Conference to be valuable, and, hopefully, it will help you to generate ideas on ways you can enhance your own compliance programs when you go back to work tomorrow.

Thank you, welcome, and I hope you enjoy today's conference.

{Concluding remarks}

As we reach the end of the National CCOutreach Conference, on behalf of Buddy, myself and the SEC staff, we thank you for attending, or for listening via the web. We hope that you will take away from today's event some practical compliance information that you can use in your own compliance programs.

I also want to thank all of our speakers - the CCOs who participated as well as our own SEC staff from Washington and many regional offices. The compliance expertise on the stage today was impressive and we are grateful. Special thanks to Karen Rossotto, Jennifer McHugh, Mavis Kelly and Shane Breffitt.

As we end today's National CCOutreach seminar, we're looking ahead and are now actively planning the CCOutreach regional seminars in 2007, which will be held throughout the country in April, May and June. Because we want these seminars to be as helpful and as relevant to you as possible, we want you to help us in the planning process. Specifically, we're asking for your input regarding the topics that you'd like to be addressed in the 2007 regional CCOutreach seminars.

The regional seminars will likely address four or five specific compliance topics. With respect to each topic, we'll address:

• the information and documents that we request during exams;
• common examination findings;
• various analyses we perform; and
• factors to consider when establishing controls in these areas.

The topics that we're considering are listed in the "handout" in your materials called "CCOutreach Regional Seminar, Possible Topics 2007" and they include:

1. the Examination Process;
2. the Risk Assessment Process;
3. Portfolio Management;
4. Brokerage Arrangements, Best Execution and Trade Allocation;
5. Personal Securities Transactions;
6. Pricing and Valuation;
7. Books and Records;
8. Disclosures and Filings;
9. Marketing, Performance Advertising and Distribution; and
10. Safety of Client Assets.

* The Securities and Exchange Commission, as a matter of policy, disclaims responsibility for any private publication or statement by any of its staff. The views expressed by the staff in these written materials are those of the staff and do not necessarily reflect the views of the Commission or of other Commission staff.

http://www.sec.gov/news/speech/2006/spch111406lar.htm