The issue of chief compliance officer (CCO) liability has long been debated; it has become a grave concern for CCOs, CEOs, and other C-suite executives who put on “too many hats” within.
The staff at the Securities and Exchange Commission's Division of Examinations (the "Division") conducts the SEC's National Exam Program. Recently, the Division issued two Risk Alerts.
SEC required to adopt Regulation S-ID by a provision in 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act, amended provision of Fair Credit Reporting Act of 1970 FCRA to add SEC and Commodity Futures Trading Commission to federal agencies must have red flag rules