Counsel Andrew Reich authored a two-part article published in the March 3 and March 10, 2016, issues of Hedge Fund Law Report. The article, “Why All Investment Advisers and Investment Companies – and Their Compliance Officers – Should Heed the SEC’s Risk Alert on Outsourced CCOs,” discusses risks and concerns regarding regarding both inhouse and outsourced chief compliance officers (CCOs). Reich notes:
[M]any of the issues and concerns addressed in the Risk Alert – such as the importance of engaged and empowered compliance officers, and the critical role played by firm leadership in establishing a culture of compliance – are likewise applicable to firms with an in-house CCO.
In the second part, Reich outlines some steps companies can take to minimize their risks and concludes:
Thus, all firms – whether or not they use outsourced CCOs – are well advised to review the issues in the Risk Alert and the enforcement cases discussed; determine the extent to which such issues apply to their firms; and consider revising their compliance programs accordingly.
Read the article.