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CCO Liability

Former CCO Meredith Simmons shares her lessons learned following an SEC enforcement action
“I would strongly recommend never finding yourself in a position where you’re alone with the exam staff." She wished she would have asked the firm’s ...
"We notice on exams when firms hire someone for the role to check the box but do not support or empower them.  We notice when ...
Goulding commingled in the same bank accounts moneys belonging to himself, Nutmeg, and the Funds
Commissioner declares CCO liability concerns have increased over the past two years
Guidance needed on decisions to charge and not to charge CCOs
Hester Peirce
"So a compliance officer who, outside of her compliance functions, directly violates provisions of the securities laws is liable the same way anyone else would ...
The settlement asserts Meredith Simmons shared the document with OCIE examiners without divulging when she really created it
Although Haupt conducted certain reviews of GGHC’s trading in 2017, she conducted no reviews for excessive trading or the impact of GGHC’s trading strategies or ...
The Commission’s complaint further alleged that, of the $2.4 million in unlawful commissions generated from the unauthorized trading, Desiderio received over $390,000

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