2019 IMCTS

Thank you for participating in the 2019 Investment Management Compliance Testing Survey, organized by ACA Compliance Group and the Investment Adviser Association with consultation support provided by BrightSphere Investment Group. Your participation in this year’s survey will assist in providing valuable information to the investment adviser compliance community. Moreover, you will gain access to a variety of testing strategies that you can put to practical use at your own firm.

This is the 14th anniversary of the Investment Management Compliance Testing Survey and each year we seek to gather information for the purpose of reporting on industry trends since the initial launch of the survey in 2006. This year’s survey covers topics in the following areas:


    • Advertising
    • Social Media
    • Custody
    • Best Execution
    • Code of Ethics
    • Gifts and Entertainment
    • Data Privacy
    • Solicitation / Referrals
    • Lobbying
    • Impact of MiFID II on Research
    • Trend Updates   
      • Cybersecurity
      • Fees and Expenses
      • Whistleblowing


The survey is open to compliance professionals at SEC-registered investment advisers. We ask that only one person per firm complete the survey. If you are not your firm’s Chief Compliance Officer ("CCO"), please check with your CCO before completing the survey, to avoid duplicative responses.

Please complete the survey no later than May 31, 2019. The survey will be closed after that date. The survey should take approximately 25 to 30 minutes to complete. The status bar at the bottom of the page will track your progress. You will not be able to save partially-completed responses, so please plan to complete the entire survey in one sitting.

Please answer candidly! The survey is conducted on a “blind” basis, so that all participants will remain anonymous. You will not be required to enter your identity, nor the identity of your firm. Moreover, all individual responses to the survey will be held strictly confidential and will not be revealed to any third party.

Please note: If you indicate that you do not test in a particular subject area, the survey will automatically skip over follow-up questions in that area, which list examples of possible tests.  

Again, thank you for participating in the survey. We plan to issue a summary of the results and conduct a webinar on the survey results on Tuesday, June 18, 2019. A full printed copy of the survey and aggregate survey data will be available to webinar participants.

Upon completing the survey, participants will receive a complimentary webinar registration code, and can register immediately for the webinar. Please make a note of the code, as you will need to enter it for complimentary webinar registration. If you have any questions, please feel free to contact either of the following individuals:

Enrique Alvarez, ACA Compliance Group           (703) 419-0747

Sanjay Lamba, Investment Adviser Association  (202) 293-4222