Sutherland News and Resources
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Sutherland Memos, Legal Alerts, & Presentations
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Completing the Rule 38a-1 Annual Compliance Review & Annual Report (1/25/06)
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Rule 38a-1: Lessons Being Learned and Future Challenges (11/3/05)
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Rule 38a-1 and Rule 206(4)-7 Implementation – Phase 2 (11/1/04)
- Designing an Effective Rule 38a-1 Compliance Program for Registered Separate Accounts (2/25/04)
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SEC Publishes Final Compliance Rule 38a-1; Special Comment Period Until February 5, 2004 (12/23/03)
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Prompt Adoption of Proposed Rule 38a-1 Seen by SEC and Some in Congress as an Important Reform to Combat Late Trading and Market Timing Abuses (11/12/03)
CCO Round Table Panel Discussions, December 2005
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Panel 1: The Responsibilities of the Separate Account Chief Compliance Officer Outline
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Panel 1: The Responsibilities of the Separate Account Chief Compliance Officer Presentation
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Panel 2: The Annual Compliance Review Outline
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Panel 2: The Annual Compliance Review Presentation
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Panel 3: The Upcoming Annual Compliance Report Outline
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Panel 3: The Upcoming Annual Compliance Report Presentation
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Panel 4: Internal Inquiries and Investigations Outline
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Panel 4: Internal Inquiries and Investigations Presentation
Sample Materials
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Rule 38a-1 Compliance Program for Separate Accounts Annual Policies and Procedures Review Matrix
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Sample Rule 38a-1 Compliance Manual for Separate Account Principal Underwriter
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Sample Rule 38a-1 Compliance Manual for Separate Account
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