NSCP Firm and CCO Liability Framework
The National Society of Compliance Professionals (NSCP) developed the Firm and CCO Liability Framework to provide clarity, consistency, and fairness in evaluating potential liability for compliance professionals. This framework offers a structured approach for regulators, firms, and CCOs to assess whether enforcement actions are warranted, particularly in cases involving compliance failures.
- The NSCP Framework is built around a series of guiding questions that help determine:
- Whether the CCO had clear responsibility and authority over the compliance function
- If the CCO acted in good faith and exercised reasonable diligence
- Whether systemic firm-level issues contributed to the failure
By utilizing this framework as a tool, firms can better support their compliance teams, regulators can make more informed decisions, and CCOs can navigate their responsibilities with greater confidence and transparency.