Think before you “fix” it: CCO missteps lead to personal fines and bar

A stark reminder that Chief Compliance Officers are on the hook for misleading regulators during an examination.

Two recent SEC enforcement actions serve as a clear reminder that Chief Compliance Officers (CCO) can be held personally liable – not for every firm misstep, but specifically for misleading regulators during an examination. Both cases involved backdated compliance records, and in each, the SEC determined that the CCO’s effort

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