“A robust training program reflects a fund manager’s compliance culture and reduces its overall compliance risk,” said Victoria Hogan, president of NorthPoint Compliance and former SEC examiner. “Aside from that looking good during an SEC examination, firms should want staff to understand their compliance policies and procedures to reduce the risk of deficiencies and violations.” In short, simply complying with Rule 206(4)‑7 of the Investment Advisers Act of 1940 by adopting and implementing a compliance program is not enough – managers should also ensure their employees are properly trained on those policies and procedures. This second article in a two-part series discusses who conducts compliance training and identifies five traps to avoid when providing training. The first article explained the SEC’s expectations as to compliance training and provided three traps to avoid in terms of the substance of a fund manager’s training. See “OCIE Risk Alert on Compliance: Inadequate Annual Reviews, Poorly Implemented Policies and Other Key Takeaways (Part Two of Two)” (Feb. 2, 2021); and “FCA Director Emphasizes Regulator’s Focus on Firm’s Culture of Compliance” (Jul. 21, 2016).