NSCP Releases NSCP Firm and CCO Liability Framework

Over the past year, The National Society of Compliance Professionals (NSCP), through its Regulatory Advisory Committee, reviewed the issue of Chief Compliance Officer (“CCO”) liability. To provide an industry perspective, NSCP conducted member surveys to assess members’ views on CCO liability and CCO empowerment and resources. As a result, the Regulatory Advisory Committee developed the NSCP Firm and CCO Liability Framework (“NSCP Framework”). The NSCP Framework provides a practical approach to CCO liability, which complements the New York City Bar Association White Paper on CCO Liability (“NYCBA White Paper”). Read together, the NSCP Framework and NYCBA White Paper provide real-world perspective regarding perceived CCO liability issues and offer guidance to regulators, CCOs, and firms regarding a legal framework for analyzing actual CCO liability while promoting investor protection and market integrity.

Special thanks to Regulatory Advisory Committee members Genna Garver, Patrick Hayes, Steven Hansen, Brian Rubin, Robert Saperstein and Heather Traeger for their leadership on this project.