CCO Liability

Add another voice to those clamoring for the SEC to dampen fears among compliance officers that they will be charged for missing the violations of ...

While the facts line up very similarly to The Robare Group’s case (see related story), the result at the ALJ level couldn’t be more stark. ...

It was all smiles in June when an SEC ALJ dismissed an enforcement action against The Robare Group ($160M in AUM) in Houston over Form ...

The policy is designed to provide personal liability coverage for CCOs at investment advisers and mutual funds

Ariston misstated in filings with the Commission that it had $32 million in AUM in November 2011 when it had less than $20 million in ...

Seasoned compliance professionals are always parsing the language in SEC enforcement actions for guidance and to glean the message being sent by the Commission.  Combing ...

The need for clear and transparent Orders is especially important when Commission actions involve federal securities law violations by Chief Compliance Officers, a subject that ...

While not condoning the deceit committed by a fired Wells Fargo compliance officer who altered records in an insider trading investigation, an SEC ALJ argues ...

TPGS violated the Custody Rule because it failed to accurately determine the securities over which it had custody; failed to ensure the securities were maintained ...

During my tenure I have repeatedly called on the Commission to tread carefully when bringing enforcement actions against compliance personnel, who are often the only ...