Patrick Campbell Comments on Potential for Clearer Liability Criteria for Compliance Officers

News / January 4, 2021

Partner Patrick Campbell is quoted in an article published by Law360 on Jan. 4, 2021. The article, “CCOs Enter 2021 Hoping for Clearer Liability Criteria,” reports on efforts to develop a framework for determining the amount of liability faced by chief compliance officers (CCOs).

Campbell serves as chairman of the New York City Bar Association's Compliance Committee, which issued a report in February citing a growing "risk of liability arising out of an assessment made in hindsight regarding what a compliance officer or program ought to have detected and prevented."

Campbell told the publication, “The NYC Bar Association Compliance Committee was pleased to see (SEC) Commissioner Hester Peirce discuss several of the proposals of our report on CCO liability" in a recent speech. He was referring to Peirce's remarks in October before the National Society of Compliance Professionals. Peirce cited the bar report in her speech and noted the danger of overenforcement.

Campbell said, "We look forward to any opportunity to work with Commissioner Peirce, the SEC, and any other interested regulator on the important topic of CCO liability."

Read the article (registration required).

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