The appropriate placement and authority of the compliance function and chief compliance officer remains a hot topic. Yet the continuing occurrence of major compliance failures raises the question of whether a better-structured compliance program and a CCO with substantial clout could have made a difference.
The General Motors faulty ignition switch fiasco is a case in point. Despite an exhaustive investigation resulting in the lengthy Valukas Report examining the failure, there is no direct mention of a corporate compliance program or the involvement of a CCO. While the Recommendations section of the report mentions a Global Ethics and Compliance Center, with reference to a code of conduct and the responsibilities of a vice president of global vehicle safety (to include safety and compliance issues), it doesn’t seem that the role of a CCO itself merited any attention.
