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Supervisory Procedures

Written supervisory procedures document the supervisory and monitoring systems that have been established to monitor and confirm that the compliance procedures are being followed and to prevent and detect prohibited practices.

In other words, licensees should implement a “surveillance program” for the purpose of monitoring compliance with the company’s obligations and detecting improper or inappropriate practices.

We believe that such arrangements are beneficial as it enables any compliance related issue to be identified (and rectified) promptly and ensure that the procedures implemented are in fact being followed.

The Compliance Officer (or related staff) should on a random sample basis, conduct reviews with appropriate internal or external support as required. The findings should be recorded (e.g. in appropriate registers such as a Compliance Activity Register) and reported through the appropriate channels (e.g. to the External or Internal Compliance Committee and/or the Board).

The report should include details of Compliance Reviews undertaken and the results, progress on issues identified in previous Compliance Reviews, including any external reviews, reporting any breaches and action taken to address the breaches, education and training conducted and any other compliance activities.

Lazorne Group Pty Ltd ATF Compliance Consulting Unit Trust can assist you in:

  1. the preparation of Compliance Plans for a registered MIS (as defined), or if not required, Compliance Monitoring Programs, together with supporting “checklists” and “certificates” to demonstrate compliance with stated policies and procedures. In other words, attesting to compliance is not considered sufficient, there should be a document “affirming the attestation of compliance”.
  2. assisting the Compliance Officer to “sample test” i.e. to confirm you are complying with your obligations, together with the preparation of a report on the work performed and reporting the findings to the External or Internal Compliance Committee and/or the Board.
  3. training the Compliance Officer in the use of the Compliance Plan / Compliance Monitoring Program to enable him/her to take over the monitoring responsibilities on an ongoing basis.