The Securities Compliance Podcast Season 5 Episode 11 – Effective Strategies for Building Your Compliance Team

Podcast

Securities Compliance Podcast: Compliance in Context

In Season 5 Episode 11 of The Securities Compliance Podcast: Compliance in Context, host and Calfee Partner Patrick D. Hayes welcomes former NSCP Chair and current CCO of Robinhood, Norm Ashkenas, to discuss how firms can build a culture of compliance inside their firms and what it takes to build out an effective compliance team. In the Headlines section, the SEC Investor Advisory Committee considered draft recommendations on mandatory arbitration clauses and the expansion of retail investor access to alternative assets (among other items), and a dually registered firm settled SEC charges for failing to timely investigate and report suspicious transactions to FinCEN. The episode concludes with an installment of What’s On My Mind, where an old quote from Winnie the Pooh might just be the best thing we can do for our friends and loved ones during the cold winter months.

Show

Headlines

• The SEC Investor Advisory Committee considered draft recommendations on mandatory arbitration clauses and the expansion of retail investor access to alternative assets.

• Dual registrant settled SEC charges for failing to timely investigate and report suspicious transactions to FinCEN.

Interview With Norm Ashkenas

• What is a culture of compliance? What does it mean? How do you know it’s present?

• How can you build a culture of compliance?

• Best practices when building out your compliance team.

• Key things to look for when sourcing and building out your compliance team.

• The importance of diversity of thought and perspective on your compliance team.

• How should firms think about compliance collaboration with other business units as part of the hiring process?

• How should firms view unique skillsets and experiences when building out their compliance team?

• Best practices when using pre-formed hiring questions or question banks.

What’s on My Mind

• Using a quote inspired by Winnie the Pooh, part of building a compliance team includes letting them know we’re there for them when they need us most.

Quotes

12:20 – “Somebody I didn’t know reached out to me via Slack and said, ‘Hey, so-and-so senior executive thought I should reach out to you because we’re thinking about doing A,' and he said, 'You should talk to Norm and compliance first to see what they think and how to get it done.' That’s what I want to have happen. It’s not about me, it’s about somebody else thinking of compliance when we weren’t there.” – Norm Ashkenas

22:15 – “If you’re asking questions, certainly you’re starting with the technical expertise. If you’re looking for somebody who does surveillance on municipal securities, they have to know a great deal about that space to start, if that’s what you want them to do. So, certainly, you’re testing for that. Obviously, you are certainly looking for culture fits, again, another overused phrase. But if your firm is the type of firm that seeks to get alignment from everybody and it's a firm where they don’t want somebody to present a solution, they want to have conversations with everybody who might be a stakeholder, get them all on the same page, and then have a final discussion, you need to find people who can do that kind of thing. If it’s a firm that’s more entrepreneurial, where it’s, ‘We want you to go solve the problems and see how many people react,’ you have to try to ask questions to glean what that is. So it does start with ‘What is your firm looking for after you hit the technical expertise?’ And then you also certainly want to ask how they fit into your overall compliance program and team. Complimentary skill sets are helpful. Like, you need... yes you want technical expertise, but in some cases, it’s ‘Am I hiring somebody to do this job in front of them for the next two or three years? Or am I hiring somebody who I think can do much more than this or different things? Am I hiring – I’ll use the phrase – a pocket knife? Somebody who’s got a multiplicity of things they can do? And I see them doing a number of different things?' Those are things you’ve got to think about as you’re doing the hiring.” – Norm Ashkenas

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About the Securities Compliance Podcast: Compliance in Context

Introducing the Securities Compliance Podcast: Compliance in Context presented by Calfee, Halter & Griswold, and the National Society of Compliance Professionals and hosted by Patrick D. Hayes, Partner and Chair of Calfee's Investment Management practice.

Designed as a personal master class for the securities legal and compliance professional, this podcast embodies Patrick’s passion to help you put Compliance In Context™ by combining the technical expertise of industry thought leaders and innovators with the practical experience of doers and key decision makers.

Listeners will find the podcast on Apple Podcast, Google Podcast, Spotify, and Stitcher.

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The opinions expressed by guest speakers and panelists during Securities Compliance Podcasts may not necessarily reflect the viewpoints of the attorneys and professionals of Calfee, Halter & Griswold LLP, or its subsidiaries or affiliates. Calfee’s educational content is intended to inform and educate readers about legal developments and is not intended as legal advice for any specific individual or specific situation. Please consult with your attorney regarding any legal questions you may have. With regard to all content including case studies or descriptions, past outcomes do not predict future results.