Commenting on the SEC’s new risk alert showing common ways in which boards fail their best execution obligations, Kelley A. Howes advised that compliance is something that needs constant attention.
“To me, compliance policies and procedures have a bit of a circular nature to them. You don’t just put them in place and walk away; you put them in place, you monitor them, make sure they’re working. If they’re not, you fix them,” she said in the Board IQ article “Risk Alert Gives Boards Map to Oversee Best Execution” (subscription required). “The board every year has to make sure there’s some evidence that monitoring is taking place.”