All New York City Bar Association articles
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ArticleSEC’s Peirce weighs CCO enforcement case against liability framework
What would it look like if the SEC adopted a chief compliance officer liability framework? Commissioner Hester Peirce offered a preview in a statement regarding an enforcement action against the CCO of a formerly registered investment adviser.
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ArticleCCO liability framework seeks to acknowledge compliance support concerns
The National Society of Compliance Professionals has drafted a framework that urges regulators to consider chief compliance officer liability more holistically, in the context of the compliance culture within a CCO’s firm.
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ArticleDistinction between CCO and company key to any liability framework
Despite best effort, a chief compliance officer has a lot to lose when his or her company faces enforcement. Acknowledging this as part of any potential CCO liability framework will be important to its success.
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ArticleNYC Bar framework seeks clarity on when CCOs face SEC charges
The New York City Bar Association has proposed a framework for regulators like the SEC to use when considering charging chief compliance officers for misconduct that occurs on their watch.
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ArticleStudy: Compliance officers in finance face ‘unnecessary risks’
Compliance officers in the financial services industry face “unnecessary risks” that undermine effectiveness and regulatory goals, according to a new report by the Compliance Committee of the New York City Bar Association.