One Year into COVID | CCOs Reflect on Lessons Learned

Compliance Conference Takeaways

One Year into COVID | CCOs Reflect on Lessons Learned

March 26, 2021


It has been almost exactly one year since the COVID pandemic pushed investment advisers into a virtual work environment – virtually overnight.

In a panel discussion at the 2021 IAA Compliance Conference, investment adviser CCOs and their counsel reflected on what the transition to “work from home” has meant for their work and their firms. The panel featured speakers Lee Faria of Columbia Management Investment Advisers, Christopher Hayes of 1919 Investment Counsel, and Jennifer Klass of Baker McKenzie and was moderated by the IAA’s Laura Grossman.

Lee Faria, CCO for Columbia Management Investment Advisers; Christopher Hayes, CCO for 1919 Investment Counsel; Jennifer Klass, Partner at Baker McKenzie; and IAA Associate General Counsel Laura Grossman


Changing practices. For all the speakers, the past year has been one of change in their operational practices. “We found things that just didn’t work as well remotely,” summarized Hayes.

For example, approaches to supervision and monitoring needed to be re-evaluated as work moved from in-person to virtual. “Most firms have been focused on coming up with a plan for how they can interact with employees in remote locations . . . to have a sense of what they’re doing and have a control environment around that,” explained Klass.

“Very early on, we reassessed the risks to our firm based on the virtual environment and the market volatility,” reported Faria about Columbia’s transition. “We made sure that our compliance program and our monitoring and oversight really focused on those areas of higher risk.”

In this same vein, 1919 Investment Counsel added more formal structure to oversight of its offices, while increasing the frequency of reviews, reported Hayes.

Faria noted that while many of the changes were expected to be temporary, they have now been in place for a long time – and many will become permanent. She recommended reviewing policies and procedures to make sure that they reflect current practices, adding, “It’s a really good time to review all your other disclosures, like Form ADV.”

Increased efficiency. But the changes to policies and procedures had a silver lining, agreed the panelists.

“We identified a lot of opportunities to be more efficient,” said Faria, explaining that some inefficiencies became “awkward” in a virtual environment. “We streamlined certain processes, maybe cutting out a middle man.”

Hayes concurred. “It forced us to take a look at what we do to be more efficient, more nimble.” More specifically, they began to automate manual processes, realizing that “we have to find a technology solve.”

Communicate, communicate, communicate. At the same, the pandemic has highlighted “the critical importance of communication,” said Faria. “People feel pretty isolated” when they can’t just turn their chair and ask a question, she explained.

She has been trying to “overcommunicate, adding that “I want people on my team as well as the businesspeople to know that we have a virtual open door policy.”

“At least for us,” noted Hayes, “Frequency has been as important as depth… We have a lot of 15-minute catch up meetings… It keeps their attention.”

Looking ahead, the panelists are bracing for a complicated return to the office. “The transition back will be equally as the transition out,” suggested Hayes.

“I encourage firms to embrace the fact that we are at an inflection point,” concluded Klass. “For better or worse, COVID has created a way to look at business before and after and to use that as an opportunity.”


TAGS: Compliance Conference, Takeaways, Columns, Coronavirus, COVID-19




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