A Deficiency Letter to (Not From) The SEC: Please Provide More Transparency When Charging a Chief Compliance Officer With Personal Liability

by Matthew L. Levine In a prior blog post we discussed the important question of whether certain regulators – especially the SEC – have undercut effective compliance programs by sending mixed signals about when a Chief Compliance Officer should be held personally liable for the actionable compliance deficiencies of his or her firm.[1] Two important … Continue reading A Deficiency Letter to (Not From) The SEC: Please Provide More Transparency When Charging a Chief Compliance Officer With Personal Liability