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International Association of Risk and Compliance Professionals (IARCP)
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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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Certified Risk and Compliance Management Professional (CRCMP)
Distance Learning and Online Certification Program
 
Certified Information Systems Risk and Compliance Professional (CISRCP) -
Distance Learning and Online Certification Program
 
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