S2:E6 | The Five Fundamentals of Compliance | Compliance In Context

Welcome back to the Compliance In Context Podcast! On today’s episode, we have the distinct pleasure of chatting with Jim Downing, the current Chair-Elect of the NSCP Board of Directors and current Chief Compliance Officer for Morningstar, who shares with us his Five Fundamentals of Compliance, and provides some fantastic insight into how best to run a compliance program that has multiple business lines and a global customer base.

In our Headlines section, we do another dive into some recent buzz and regulatory activity surrounding cryptoassets, we’ll cover a defense of family offices from a couple key regulators, and finally, we’ll wrap up today’s show with another installment of What’s On My Mind, where in the spirit of this year’s Olympic games, we look back at a quote from the greatest sprinter of our generation to help provide peace of mind to compliance officers everywhere, no matter the stage in their career. 

Headlines

• Letter from Senator Warren to SEC Chair Gensler
• Expanding the authority of the SEC or the CFTC to regulate cryptocurrency exchanges
• Bloomberg Op-Ed from SEC Commissioner Hester Peirce and CFTC Commissioner Brian Quintenz focused on the regulation of family offices
• Examining the risks involved in the failure Archegos Capital Management

Interview

• How to build a diverse and global compliance program
• Developing a culture of compliance
• Understanding the Five Fundamentals of Compliance

• Identifying and mitigating conflicts of interest in multi-faceted firms

What’s on My Mind

• Quote from Usain Bolt on setting the proper expectations
• Understanding and overcoming the challenges in running a compliance program

Quotes:

“One of the first things to do is to check your ego at the door. So when it comes to a global compliance program, I have to realize what I don’t know. And so when we look at, let’s say, Aon or my current position at MorningStar, there were several jurisdictions where I could--in no way--consider myself an expert. So what’s really important there is you make sure you have the right talent onboard.”

“It’s so important to, number one, when you first get there and you first start meeting these executives or heads of sales or product, or operations, or finance, or all the various compartments, is to really take some time and to sit down and to listen to them.”

“Because that’s the advice that we're giving the business on kind of a day-to-day basis you know. When they come to us “Hey what should I do about this?” or “I'm thinking about doing this, what do you think?” And that advice should be drawing from all of these five different fundamentals, you know it should be drawing from where's our where's what's our most risky behavior? It should be drawing from what do our policies and procedures say? It should be drawing from, well, you know, we tested that process and they’re talking about they want to increase the capacity of that and that wasn't very good or hey we had a recent exam or there’s an outstanding issue or whatever it is.”

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Compliance in Context