What would it look like if the Securities and Exchange Commission (SEC) adopted a chief compliance officer liability framework? Commissioner Hester Peirce offered a preview in a recent statement regarding an enforcement action against the CCO of a formerly registered investment adviser.
Jeffrey Kirkpatrick reached a settlement with the SEC published June 30 in which he agreed to pay a $15,000 penalty, cease and desist from future violations of securities laws, and be limited from acting in a supervisory or compliance capacity for a period of five years. Kirkpatrick served as principal and CCO at Georgia-based Hamilton Investment Counsel (HIC), which was fined $150,000 for failing to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act.
