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CCO Liability
Robert Hackenbergโs 40-year career as a CCO of his RIA ended with an SEC enforcement blemish that speaks to challenges compliance officers can face if ...
The CCO who admitted to the behavior received a $10,000 fine; the secondโwho didnโt cop to the backdatingโgot a $40,000 fine and a bar from ...
Rather than responding that he didn't have any records responsive to the staffโs request, Moors created three documents entitled Annual Compliance Calendars and purported to ...
The adviser erroneously billed and collected advisory fees on alternative investment positions, although no fees were supposed to be assessed on those positions
The most common alteration Ballek made to documents submitted to examiners was changing the dates the forms were signed by the portfolio manager or herself ...
Lessons that can be drawn from this case include to exercise extra scrutiny of trust accounts to ensure money isnโt being transferred illegally to an ...
Dual-hatted CCOsโoften holding additional titles like president, CEO or principalโnumber about 20% of the population
It can pay to have checks and balances in place, but only if the check does the job thoroughlyโespecially if the monitor holds the title ...
"As chief compliance officer, [he] had 'overall responsibility for monitoring and testing compliance with the Firmโs policies and procedures'โ
The lies ran as deep as a biblical flood. Wright allegedly told investors he put his own money into the investment. 'Wright had invested no ...









