TILLIESTAR COMPLIANCE SOLUTIONS Compliance Software Implementations • Compliance Software Upgrades • Compliance Software, Data & Workflow Enhancements “Is compliance handled with pencil and paper? Does the firm look for ways to automate compliance and limit human error, as it does with portfolio and risk management? How are workflows and documents managed? Technology allows firms to spend less time managing paper and people and more time actively managing risk, something the SEC likes to see.” “I carry firmly the faith that the forces of life are eternal, immutable and ever present. In the ultimate analysis, I am neither favored nor deserted. No one is.” – K.S. Narendran. “You’ve heard it from Chairmen, from Commissioners, and from the staff, and certainly you’ve heard it from me. If you’ve been listening, you know it’s not enough to have policies. It’s not enough to have procedures. It’s not enough to have good intentions. All of these can help. But to be successful, compliance must be an embedded part of your firm’s culture.” – Lori A. Richards Director, Office of Compliance Inspections and Examinations U.S. Securities and Exchange Commission, April 23, 2003 “In 1920, long before the SEC was established, Charles Ponzi was able to keep his scam running and undetected for only eight months. Fortunately, this fraud quickly unraveled when local media began to raise and followed up on some basic risk-related questions. The Madoff case and the failure of early detections is a further indication that the SEC should move to a more risk-focused approach.” – Mark T. Williams, a finance professor at the Boston University School of Management, is a risk-management expert and former Federal Reserve Bank examiner “It is not sufficient for [a supervisor] to be a mere bystander to events that occurred.” – In re John H. Gutfreund, Exchange Act Release No. 31554 (Dec. 3, 1992).