No, that’s not my current Facebook status, but it could reflect the status of the Blue Sky compliance environment today. This was one of the themes at the inaugural Blue Sky Client Roundtable hosted at Boston Financial in April. At this event 25 representatives from 20 different client firms discussed the intricacies of managing a Blue Sky program, and best practices for navigating the filing and sales reporting process.
We know our clients have major questions about Blue Sky compliance, dominated by a concern about the vast unknowns that often surround their work. This may be the result of
- Loss of in-house expertise as the industry has shifted to full service outsourcing of the Blue Sky functions.
- Assignment of Blue Sky oversight responsibility to people who may not have state compliance experience.
- Shifting nature of Blue Sky laws within the 53 states and territories that require Blue Sky notice filings.
Management of Blue Sky is complicated
So, taking a page out of Boston Financial’s Client Forum and CCO Forum, the Blue Sky Administration team made the decision to create a professional community exclusively for our Blue Sky clients.
The community will feature:
- In-person events like the Roundtable.
- Virtual learning and networking opportunities.
- Core education for Blue Sky oversight staff on Blue Sky processes and Boston Financial’s management of their programs.
It will also be a place where clients can discuss cutting edge themes in the industry, and safely exchange ideas and build on the experiences of each other so they can stay ahead of the regulatory curve.
Case in point:
Just days before the Boston Financial Blue Sky Roundtable, I attended a meeting for the ICI Blue Sky Subcommittee in Washington DC, where we discussed whether funds are correctly reporting the required sales amounts to the states using all exemptions available.
At the Roundtable, we shared the themes from this ICI dialogue, and introduced the participants to the best practices we use in managing sales reporting and exemptions; an exemption decision workflow was distributed to help clients manage their responsibility for exemption processing. During the afternoon panel discussion about sales reporting and an open Q&A session at the end of the day, Roundtable participants shared their thoughts and experiences improving data used to make exemption decisions.
During the April 2016 ICI Blue Sky Subcommittee meeting, we also discussed whether or not states were becoming more aggressive in their enforcement of Blue Sky. Within a month, we released notifications via our secure client extranet site, of two more states amending their Blue Sky regulations to increase fees. This brings the number of states making changes to their fees to four in just the past 12 months.
As the event came to a close, one Blue Sky Roundtable participant expressed what many were thinking:
It (is) great having other Boston Financial clients to discuss Blue Sky best practices with, and also just to have a general understanding of how different companies handle their Blue Sky needs compared to our company.
Management of Blue Sky is complicated. This is why we are building a client community that features events like the Blue Sky Roundtable, where we can educate clients, provide guidance and best practices, and together explore strategies for meeting evolving compliance needs.