NYC Bar Proposal Could Quell Persistent 'Fear' CCOs Face
Law360 (June 9, 2021, 4:57 PM EDT) -- The lack of clarity surrounding U.S. regulators' decisions to bring enforcement actions against chief compliance officers has brought an atmosphere of fear and uncertainty to the profession, a problem that a new proposal from the New York City Bar Association could help solve, according to industry experts.
The proposal lays out over a dozen factors the City Bar wants regulators, including the U.S. Securities and Exchange Commission, to weigh when deciding whether to take enforcement actions against chief compliance officers, or CCOs.
For example, the proposal includes questions about whether a CCO's actions constituted a "wholesale failure," suggesting that enforcement actions...
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