2012: The Year of the Dragon and Dodd-Frank Compliance
Happy Holidays and Happy New Year from DocDep! 2011 was an exciting year for us, with a shift in strategy, new products and exciting growth. And 2012 promises much more, especially with the arrival of Dodd-Frank. You could be forgiven for thinking that 2011 was Dodd-Frank’s big debut. Between the Republican presidential candidates lambasting and promising to repeal the law and Congressman Barney Frank’s retirement announcement, the 2010 Wall Street Reform and Consumer Protection Act has received a lot of attention this year. But 2012 is the year that Dodd-Frank compliance will really come to the fore. Next year, we’ll be done talking and financial agencies will have start acting.
Many Provisions Still Coming
Many major provisions of the Act have not yet taken effect, including the requirement that firms with more than $150 million in assets under management register with the SEC. Under this requirement, the SEC can require a firm to produce many key documents – everything from corporate governance policies to financial records to proxy voting policies.
This might seem like a daunting list of requirements, making the SEC as intimidating as the IRS. Steve Randolph of the consulting firm Oakbrook Solutions notes that this will even ensnare some family-owned firms. But investors and fund managers should not fret. All that's required to meet this provision of Dodd-Frank is some strong, clear corporate governance and document management. DocDep has developed an application that will help firms develop this organization and reporting system. The application offers a storage and maintenance platform to keep track of corporate and financial records, secure locations for marketing materials and portfolio management tools.
We know that Dodd-Frank is very controversial and sure to cause a lot of headaches as it rolls out. But for alternative investment firms, SEC registration does not have to be very onerous. Leave the real worrying for the rest of the bill, which, according to Bill Sheridan of CPA Success, is only one-fourth enacted. Including that darn Volcker Rule!
Nevertheless, all of us at DocDep hope you and your firm have a happy and prosperous new year!
(Image: Wordle of the entire text of the Dodd-Frank Wall Street Reform and Consumer Protection Act)