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CCO reporting to a board

Tom Fox | March 27, 2018

Reports from chief compliance officers presented to a board of directors and/or compliance committee must be structured carefully to promote ethics and compliance. Here are five best practices to help guide the reporting.

Quarterly reports. The CCO should report in person to the compliance committee every quarter. If the CCO submits a written report and does not appear before the committee, it reflects a defective relationship. The quarterly report is critical for both the CCO and the committee to hear about compliance performance and challenges.

Executive session. Every quarterly report should be concluded with an executive session where the CCO and compliance committee can have a frank discussion on any potential issues. It is a valuable opportunity to raise important issues. An executive session demonstrates that the CCO is independent and empowered within the organization and reinforces the CCO’s direct access to the board.

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