CCS leads the industry with its multifaceted, ongoing client engagement process:
Most significantly, CCS staffs every client relationship with a team of at least two professionals, unlike other headhunter-like “body shops” that merely give you a portion of a person.
The senior member of the team, who usually serves as CCO, owns the technical quality and content of all elements of the CCS compliance program including ensuring that each client’s compliance program meets all regulatory requirements and incorporates industry best practices. The program manager ensures delivery of all services, rapid response, and coordination of resources by following a customized compliance calendar and project plan, which includes ongoing communications. The service team leverages all of our resources to best service your compliance needs, including the marketing review team and senior management. We determine the service team based on domain experience and availability per our internal timekeeping and allocation system. In general, we try to limit CCO relationships to no more than five per person. We also try to limit allocated hours to no more than 2000 per year.
The service team follows a comprehensive engagement and communications schedule. CCS commits to no less than six on-site visits per year to conduct a range of scheduled activities including testing, reporting, information exchange, and training. Consequently, no SEC exam will occur more than two months since CCS personnel met with the client in person. Additionally, depending on schedules, CCS management will also conduct periodic on-site visits to assess client satisfaction and discuss strategic initiatives and support.
To ensure ongoing information sharing, CCS also schedules weekly compliance calls with our internal liaison. CCS prepares both the agenda and the minutes for these calls. Topics typically addressed include new business initiatives, employee changes, code of ethics reporting, testing, annual reviews, and the progress of service initiatives. These calls serve as a great weekly check-in to ensure no piece of information goes unnoticed and no question is left unanswered.
Our relationship begins with an intensive onboarding process in which the service team and the onboarding team come on-site to take over the compliance work. During this two- to four-hour meeting, we will receive information, download documents, and begin the work of implementing the compliance program.
Of course, we are also always available by phone and email. We commit to responding to every request within 120 minutes and provide an answer within 24 hours. Our marketing review team commits to turning around every piece of marketing with required disclosures within 24 hours (or more quickly if an emergency). If, for some reason, your primary point of contact does not respond within acceptable time periods, you will have the cell phone number of each member of the team to ensure “up-the-ladder” service accountability.
We also have licensed a file sharing application (Box) so that you always have access to your compliance documents. No more will you have to ask your outside compliance firm to email you the most recent compliance manual or the minutes from the last compliance meeting. All materials are immediately accessible in shared files.
All client engagement activities are managed and supervised by the firm’s director of client engagement, one of the firm’s senior leaders.