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CCO Liability

Ben Anderson, principal with Anderson PLC in Minneapolis, shares actions he believes CCOs can take to reduce their risk of being charged in an SEC ...
“We keep just a simple Excel spreadsheet” to document issues and their resolutions
DB Fitzpatrick “terminated the chief compliance officer at the time of the Contributions and hired a new chief compliance officer
The case marks just the latest bad news for small-firm managers with compliance duties
Compliance "officers remain concerned that their good faith efforts and well-intentioned conduct may be punished"
"We have recognized previously that other demands on a CCO’s time may be a mitigating factor and [recognize] competing demands on" the CCO's time as ...
It doesn't always pay to listen to the boss
Settlement follows criminal case plea that could land the CCO in jail
Advisers systematically overbilled more than 100 of its client accounts for a total amount of over $11.8 million
RJ Advisers’ policies and procedures required FAs and the Compliance Department to monitor the Inactive Accounts. Specifically, FAs were to “continually monitor their client accounts,” ...

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