As a follow on to my recent post concerning my attendance at the NSCP annual meeting, I want to share with you the speech that was given by Andrew Ceresney, Director, Division of Enforcement of the SEC. Briefly, his remarks centered around a Chief Compliance Officer’s (CCO) liability at investment advisor firms. The three takeaways from his remarks were that CCO’s have the Commission’s full support; enforcement actions are brought against business line personnel in appropriate circumstances where the CCO has been deceived or misled or inadequate resources have been provided to help you do your job; and finally, there has been no change in the Commission’s approach to determining whether to charge a CCO. For Mr. Ceresney’s speech in its entirety here is the link.
