NSCP Webinar: Current Issues in CCO Liability

What is keeping you up at night? CCOs can answer this easily: the threat of personal liability if our company fails to comply with regulations. As many NSCP members know, panels at the 2016 SIFMA C&L conference in Orlando conducted feverish discussions on CCO liability and the often impossible position in which CCOs can find themselves with regulators. For instance, how does compliance provide a “credible challenge” to management, and what kind of evidence will the OCC be looking for? What did the SEC mean by its position that CCOs have responsibility for the implementation of compliance programs under 206(4)(7)? And those are just two of the agencies regulating financial services firms.

As discussed in the April issue of NSCP’s Currents, the reality is that the proliferation of regulations, combined with the changing state of our markets, means that firms will require an “Uber Compliance Officer,” proficient in algorithmic trading, complex legal structures, derivative products, and the global marketplaces. At the same time, that person has to be mindful of administering rules and procedures that are not implemented or followed by management.

Jerry Baker, former Executive Director at SIFMA Compliance & Legal Society; Don Andrews, Venable partner and former Bessemer Trust CCO; and Michael Manley, Venable partner and a former investment adviser CCO and General Counsel, will lead an interactive discussion on the current role of the CCO and best practices for the way forward for them in this new environment.

Attendees of this webinar will learn:
• Effective reporting to management
• Effective compliance training for all levels of the operation
• Managing the “regulatory pile-on”
• The role of and effectively using outsourced CCOs
• The potential impact of the DOL Fiduciary Rule on CCOs