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Asset Management RFPs – An Overlooked Source of Compliance Risk

RFP responses are a critical component of how business is done in the asset management and wealth advisory segments.

Seismic
Seismic
June 25, 2015

RFP responses are a critical component of how business is done in the asset management and wealth advisory segments. As marketing deliverables go, however, they’re not very sexy or exciting.

At many firms, in fact, they’re generally treated as check box items, and the teams that produce them are far from center stage at their firms.

These realities help explain why roughly half of the respondents in a recent survey of asset management firms said their shops don’t ensure that finalized RFPs are reviewed by their compliance teams before being sent out. The survey, cited in a recent FundFire article, was conducted by the Professional Association of Investment Communications Resources (PAICR) at the group’s annual RFP conference.

The survey also found that only 51% of respondents’ RFPs are reviewed by distribution teams before they’re shipped off to consultants, prospects or clients. Another key finding is that 26% of the firms surveyed don’t require any approvals or sign-offs other than that of their RFP production teams.

Survey participants did cite legitimate reasons why all finalized RFPs don’t get full compliance reviews. One reason is the frequent use of stock (and pre-approved) answers to often-asked questions. Another is that production teams only forward the sections with customized responses to compliance for review, rather than the full, finalized RFPs.

Nonetheless, RFPs that get sent out without prior review and approval are a source of potential compliance problems. That’s because they’re client-facing documents that include descriptions of the firm’s investment products and services, including:

  • Descriptions of the firm’s investment philosophy and key team members
  • Five-year history of the firm’s assets under management (AUM)
  • Explanations of any significant year-to-year changes in AUM totals
  • Descriptions of the investment strategy and objective for each product
  • One-, three- and five-year performance histories for each product
  • Products’ ratings and performance against peer products and benchmarks

Although compliance infractions would only be triggered by mistakes or misstatements of a material nature, why take the chance? With today’s changing regulatory requirements and aggressive enforcement environment, firms should identify and address all sources of potential compliance problems.

That means it’s time for asset management and wealth advisory firms to stop treating RFPs as mundane, mostly standard deliverables. By working more thorough compliance reviews of these important documents into their production processes, firms can sidestep these risks.

  • asset management
  • compliance
  • wealth management

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