CCO Liability

Requirement on CCO has SEC Commissioner Hester Peirce concerned about "undue pressures" being placed on CCOs

Several GC/CCOs tell RCW that they would separate the roles if they could

The Form ADV brochures failed to disclose information about an unpaid $208,700 judgment against Clark and Soteira in favor of a former client

Buttonwood and McGraw therefore had a financial conflict of interest with their clients—they had an incentive to select investments for clients that would allow Buttonwood ...

By making the false and misleading statements about the fee markups in its Firm Brochures or otherwise, Roberts and TCFG violated the fiduciary duties they ...

This tool comes courtesy of Ben Anderson, principal with his law firm Anderson PLC in Minneapolis

Korth did not have policies and procedures concerning riskless principal transactions until March 2018. The policies and procedures Korth adopted in March 2018 were not ...

Regal’s compliance manual designated Yarch with implementing Regal’s compliance program as well as monitoring and updating Regal’s Form ADV disclosures. In November 2019, Regal adopted ...

"If, as has sometimes happened in the SEC’s, FINRA’s, and other regulators’ enforcement actions, when a firm violates the law, the regulatory consequences fall in ...

The line around CCO liability often is drawn by whether a compliance officer participated in an alleged fraud. In a new civil lawsuit filed in ...