November 19, 2020 

 On behalf of the U.S. Securities and Exchange Commission, I send best wishes to 

attendees at this year’s Compliance Outreach National Seminar for Investment Advisers and 

Investment Companies. 

An effective regulatory environment is one that drives a culture of compliance and 

prevents problems before they occur. Our focus on transparency and our engagement with 

investors and other market participants are key parts of the Commission’s efforts to promote a 

culture of compliance. 

In keeping with that spirit, the hallmarks of the compliance outreach program are 

engagement and communication—between SEC staff and Chief Compliance Officers and other 

senior officers of registered investment advisers and investment companies—to share 

information about risks, priorities and deficiencies observed in examinations or investigations 

and to discuss examples of effective compliance practices observed by the staff. This sharing of 

information and perspectives in turn improves the quality and transparency of firms’ 

relationships with retail investors. 

There are many important topics to be discussed at this year’s program, including 

management of conflicts of interest, information security, business continuity, recent regulatory 

developments, and issues affecting retail investors. Communication on these topics will help 

ensure that market participants are focused on current issues, planning for the future and aware 

of effective compliance practices. 

As just one example, Commission staff have been dedicated to providing resources and 

assistance with submitting effective relationship summaries using Form CRS. The summaries 

enable investors to better understand the services they can receive and how they will be charged 

for those services. I recently issued a joint statement with Dalia Blass, the Director of the 

Division of Investment Management, and Brett Redfearn, the Director of the Division of Trading 

and Markets, to discuss one aspect of the form in particular: the section that allows retail 

investors—for the first time—to view at a glance whether or not a firm or its financial 

professionals have a reportable disciplinary history. Our statement, which accompanied staff 

FAQs on the subject, highlighted observations regarding firms that did not provide an adequate 

response to the disciplinary history question on the form and brought attention to FAQs issued 

about the disclosure requirements of Form CRS. The discussions today will continue to build on 

these observations and provide additional communication on effective practices. 

Communication is also important in preparing for the future. For example, preparation 

for the transition away from LIBOR is essential for minimizing any potential adverse effects 

associated with LIBOR discontinuation. The risks associated with this discontinuation and 
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transition will be exacerbated if the work necessary to effect an orderly transition to an 

alternative reference rate is not completed in a timely manner. This work should be well 

underway, and the discussions today serve as a reminder of the need to proactively manage this 

transition and to focus on creating a compliance program that is prepared for the future. 

There are many other issues to be discussed at the program, and we at the Commission 

remain committed to providing feedback and assistance so that firms are ready to address the 

important issues affecting retail investors today. 

Best wishes for a successful event. 

Sincerely, 

Jay Clayton 

Chairman