Can We Calm Down Over CCO Liability?

cco liability

Thank the lord! Yesterday the SEC fined an investment advisory firm and one of its senior managers for failure to prevent insider trading—and did not fault the firm’s chief compliance officer. Now maybe we can all, finally, step back from the fears over CCO liability that have gripped this profession too much. The firm in question…

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Thinking About Accredited Investor Standards

The Securities and Exchange Commission recently convened a meeting of its Small Company Advisory Committee. Normally news like that would not be big news for securities professionals, except for one point of discussion: overhauling the definition of an accredited investor. We can probably all agree that the current definition is outdated. It was adopted in 1982, and based…

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Compliance Careers Might Get Interesting, Part II


There we were, me and a small group of compliance professionals, talking shop about where good compliance officers come from these days. One person, a recruiter for asset management firms, told the tale of how she recently placed a chief compliance officer at a hedge fund in the Midwest. This CCO was “a dream candidate,”…

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Can Speak-Up Culture Go Too Far?

Compliance professionals talk all the time about the importance of a rigorous corporate culture and tone at the top—but rarely do we see such a vivid example of those two items like we did earlier this month thanks to the management spat at Bridgewater Associates, a huge hedge fund in bucolic Connecticut. Compliance officers couldn’t…

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