Published on Apr 25th, 2022 |

Brief Introduction

Vigilant’s Chief Operating Officer, Chuck Martin, was quoted in BoardIQ where he discussed his initial thoughts and analysis towards the 2022 Exam Priorities.

If you have not seen the Exam Priorities, click the button below to view Vigilant’s breakdown and key takeaways.

2022 Exam Priorities – Vigilant Overview

Vigilant’s Chief Operating Officer, Chuck Martin, Provides Statements Regarding the Exam Priorities 

Chuck Martin, MBA, provided statements towards the SEC’s Key Focus Areas stating his thoughts towards the new addition.

  • Chuck stated, even though the wording of “significant focus areas” was new, his impression was that the overall message of the priorities release was in line with previous ones.
  • With Chuck being involved in Examinations, he added, “But reading this and also being part of examinations, I don’t see a material shift in the approach to examinations,”

He also provided statements towards SEC Chairman, Gary Gensler’s approach compared to Former SEC Chairman, Jay Clayton’s approach.

  • As some were worried that SEC Chairman, Gary Gensler’s, first release would signal a substantial departure from Former SEC Chairman, Jay Clayton, Chuck added, “I don’t think there has been a material change about how you read last year’s priorities or even prior years’ priorities. I don’t see a different tone,”
  • He added, “Clayton was pro business and Gensler would be back to the Mary Jo White type of approach,” when comparing both of their approaches.

An important takeaway from Examiners towards Compliance Programs and Supporting the entire Compliance function was also mentioned in the BoardIQ article below.

  • Examiners wrote, “As we have all experienced over the last couple of years, significant unanticipated events can occur as well as more incremental change that can compound over time or across operational lines, causing once effective policies and procedures or controls to become weak or ineffective,”
  • The Examiners provided an addition quote towards Compliance Programs stating, “Compliance programs and related policies and procedures are not ‘set it and forget it’ endeavors, and having a process in place to address new compliance risks and challenges is critical to resiliency.”
  • The SEC expects firms to enable full support for the entire Compliance function and to not rely on an individual Chief Compliance Officer, these points have been repeatedly made over the years, especially towards policies and procedures for Firms on new Rules and Regulations that become effective.

If you need any Compliance Support or assistance related to the Examination Priorities, contact us today to learn more!

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Full BoardIQ Article Is Below:

BoardIQ Exam Priorities Article