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News July 12, 2004 Issue

Have You Heard?

If you havenít got your compliance consultant lined up to help you with your compliance program by now, you might have to wait until after October 5.

"Theyíre all booked up," said one West Coast compliance officer. "Itís just a very busy time."

If youíre in that boat, hereís some advice from one in-demand consultant: do your best to get your policies and procedures together, and schedule your consultants to come in as soon as they free up in the fall ó even if thatís after October 5. People revise and improve their policies and procedures all the time, he noted.

If you have the money, you could retain outside counsel to help you cross the finish line. While most major law firmsí investment management practices already are quite busy with enforcement-related work, several said they could accommodate additional compliance program work, one way or another.