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The Role of the Chief Compliance Officer (CCO)
There is an interesting speach about
the role of the Chief Compliance Officer:
Ownership of Corporate Responsibility
by Commissioner Cynthia A. Glassman, U.S. Securities and
Exchange Commission, American Society of Corporate Secretaries,
Washington, D.C., September 27, 2002
"In terms of trying
to personify the corporate conscience, there is something not
specifically required, but which I feel is essential
nonetheless.
While the CEO cannot delegate his or her ultimate
responsibility, to fully carry out the mandate of Sarbanes-Oxley
and the Commission's rules, a company should have an officer
with ownership of corporate compliance and ethics issues, and of
what
Title III of Sarbanes-Oxley broadly refers to as "Corporate
Responsibility."
While every company must assess its particular needs
based on the size and nature of its business, there are several
characteristics that I would want the corporate responsibility
officer to have if I were relying on this person:
He or
she should have sufficient seniority and authority to take the
actions necessary under the circumstances. To assess whether
your corporate responsibility officer meets this requirement,
ask yourself if the person would be able to address the
worst-case scenario.
The position should have the
full support of the CEO and senior management, both in theory
and in practice.
The corporate responsibility officer should have access and
provide regular reports to senior management. In this regard, he
or she can play an important role in helping a company meet the
information gathering and reporting requirements contained in
the Commission's new internal control and certification rules.
Although regular board reports on compliance and controls
seem advisable, even if they do not occur regularly, the
corporate responsibility officer should have the ability to
report directly to the board (for example, to the audit
committee chairman) on matters of significant import to the
company or matters involving misconduct by senior management.
In addition, the responsible officer should have sufficient
time and adequate resources to implement the company's corporate
responsibility program in an effective manner. The best written
code of ethics will be worthless if the company starves the
budget of the officer who has to implement it.
Case Study
Job Description
Chief Compliance Officer
(Financial Services)
About our client
Boutique Asset Manager
Job description
The Chief Compliance Officer will cover a broad range of
Investment Advisory compliance responsibilities including but
not limited to;
-
registration of firm with the SEC
- drafting and updating
policies & procedures
- annual review, testing & monitoring
- keeping the firm up to date with new legislation and all
required filings.
The chief compliance officer should have a senior level
of experience in traditional asset management compliance.
The role is with a dynamic and growing alternative asset
manager with a real estate focus.
What's on offer
Compensation & Benefits will be extremely competitive.
The ideal Chief Compliance Officer candidate will have:
- Bachelors Degree
- 7 - 15 years of legal or compliance
experience
- Strong knowledge of alternative assets
including real estate investments required
- Dynamic
personality, excellent communication skills and a strong
functional compliance skill set
- Understanding of the
Investment Company Act of 1940 and The Investment Advisers Act
and other applicable federal and state regulations.
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