CCO Liability: Enforcement Director Speech & Update
This article discusses the issue of CCO liability.
December 08, 2023
Tags: CCO, Compliance, SEC Enforcement
SEC Fines Investment Adviser CCO for Failure to Carry Out Compliance Responsibilities
This case underscores that the SEC will bring enforcement cases against CCOs who have not themselves engaged in misconduct where there is a “wholesale failure” to carry out compliance responsibilities.
July 20, 2022
Regulatory Game Changers on the Horizon
The SEC has unleashed a flurry of rule proposals that, if enacted as proposed, will significantly alter the regulatory, disclosure and reporting obligations for managers who cater to the private fund market.
May 31, 2022
Tags: CCO, Compliance, Private Funds, SEC Enforcement, SEC Examinations
FINRA Publishes Guidance on CCO Liability
FINRA recently published guidance outlining when CCOs’ role is advisory and when CCOs may be liable for failing to discharge their supervisory responsibilities.
March 29, 2022
National Society of Compliance Professionals Releases CCO Liability Framework
The framework looks to clarify the role of CCOs when determining their personal responsibility for a firm’s potential compliance failures
January 18, 2022
New York City Bar Recommends SEC Framework for CCO Liability
Following a report issued in February 2020 on how the SEC should consider potential liability for chief compliance officers of financial services firms, the New York City Bar Association Compliance...
June 15, 2021
Tags: CCO, Compliance, Enforcement
Senior staff from the SEC’s Office of Compliance Inspections and Examinations (OCIE), the Division of Investment Management (IM) and Division of Enforcement’s Asset Management and Cyber Units joined together on...
November 24, 2020
Tags: CCO, Compliance, Examinations
NY City Bar Association Issues Report on CCO Liability: New Recommendations for the SEC
April 17 2020
April 27, 2020
Tags: CCO, Guest Column, New York
SEC to Hold Virtual Compliance Outreach Program on November 19
The SEC will be holding a virtual compliance outreach program for CCOs and other senior personnel at investment companies and investment advisory firms on November 19. According to the SEC...
October 09, 2020
Tags: CCO, Compliance
SEC’s Peirce Calls for Framework to Provide Guidance on CCO Personal Liability
SEC Commissioner Hester Peirce has once again raised concerns about personal liability of CCOs and the lack of SEC guidance in this area, this time urging development of a framework...
October 27, 2020
Tags: CCO, Compliance, Hester Peirce, SEC Enforcement