The Office of Compliance Inspections and Examinations has a program designed to encourage discussions about compliance issues among commission staff, chief compliance officers and senior officers of registered investment advisors and investment companies, Aguilar said.

“The most important thing about being an investment advisor is that you are ultimate fiduciaries to your clients. And one of the cornerstones of such a responsibility is an effective and robust compliance program that is embedded into an entity’s investment culture from top to bottom. The success of your business depends largely on investor trust and confidence,” Aguilar said.

“The potential costs of serious compliance failures and violations of the federal securities laws can be much higher than any sanctions imposed by regulators. In the end, the reputational harm to your business may be more severe,” he said.

"In the end, it’s important to do what’s right according to the letter of the law, but it’s better to think in terms of doing what’s right because it is in the best interest of the client—and that is the real foundation of a culture of compliance,” Aguilar said.

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