And then there are the consequences of limited market discipline. For all its tremendous growth over the last several years, CLICO has remained a private company which has shielded the company from the kind of scrutiny (through, for example the submission of quarterly accounts) to which public companies are exposed.
The frequency of testing should be risk-based and should involve, as appropriate, sample transaction testing, the sample size being determined by volume and the degree of risk of the activity. Examiners will carefully assess the scope and quality of the testing of the compliance program. Part of this assessment will include determining whether the testing was performed with appropriate independence.