Eccleston Law: For Investors. For Advisors
About
Who We Are
Testimonials
Disclaimers
Attorneys
For Advisors
Broker Transition
Transition Negotiations
Employment Matters
State Registration Problems & Discipline
FINRA Matters
Promissory Note Matters
Team/Parnership Disputes
CFP Board Matters
FINRA Enforcement Matters
State Registration Problems & Discipline
Transition Negotiations
Broker Litigation & Arbitration
Employment Matters
Regulatory Matters
Strategic Consulting
Whistleblower Law
Promissory Note Matters
Compliance Protection
Lawyer Referral Network
Expungement of CRD/BrokerCheck Disclosures
For Investors
Securities Fraud
Breach of Fiduciary Duty
Negligent Investment Management
Unauthorized Trading
Lawyer Referral Network
News & Articles
News
Articles
Financial Counsel Blog
Videos
Newsletter Signup
Contact
Site Menu
About
Who We Are
Testimonials
Disclaimers
Attorneys
For Advisors
For Advisors: Overview
Broker Transition
Broker Transition Overview
Transition Negotiations
Employment Matters
State Registration Problems & Discipline
FINRA Matters
Promissory Note Matters
Team/Parnership Disputes
CFP Board Matters
FINRA Enforcement Matters
State Registration Problems & Discipline
Transition Negotiations
Broker Litigation & Arbitration
Employment Matters
Regulatory Matters
Strategic Consulting
Whistleblower Law
Promissory Note Matters
Compliance Protection
Lawyer Referral Network
Expungement of CRD/BrokerCheck Disclosures
For Investors
For Investors: Overview
Securities Fraud
Breach of Fiduciary Duty
Negligent Investment Management
Unauthorized Trading
Lawyer Referral Network
News & Articles
News
Articles
Financial Counsel Blog
Videos
Newsletter Signup
Contact

OCIE Warns against Outsourcing CCOs to Third Parties

Posted on November 20th, 2015 at 9:23 AM
OCIE Warns against Outsourcing CCOs to Third Parties

From the Desk of Jim Eccleston at Eccleston Law LLC: 

A November Risk Alert detailed that, after much examination of investment advisors and companies, OCIE staff recognized several downfalls accompanied with outsourced CCOs, including compliance policies and procedures failures, risk assessment inconsistencies, and the inability to conform compliance manuals to companies’ businesses and practices.

OCIE staff conducted about twenty examinations on registered SEC investment advisors and companies that outsource their CCOs as part of their Outsourced CCO Initiative. OCIE stated that the main purpose of this Risk Alert was to raise awareness of the numerous compliance issues that arise when companies outsource CCOs to unaffiliated third parties. The Commission stated that a fund’s CCO should be “competent and knowledgeable regarding the federal securities laws and should be empowered with full responsibility and authority to develop and enforce appropriate policies and procedures for the fund.” OCIE staff also noted that the outsourced CCOs used standardized checklists to gather information, but the staff cautioned that the use of generic lists do not fully capture business models, practices, or strategies. The staff hopes that the publication of this assessment will allow business to properly asses the work from their outsourced CCOs, and fix any weaknesses in their compliance programs.

The attorneys of Eccleston Law LLC represent investors and advisers nationwide in securities and employment matters. Our attorneys draw on a combined experience of nearly 65 years in delivering the highest quality legal services. 

Related Attorneys: James J. Eccleston

Tags: Eccleston, Eccleston Law, Eccleston Law LLC, James Eccleston, SEC, CCO, OCIE

Share

Return to Archive

Latest Articles
FINRA Bars Former Goldman Sachs Banker After Expense Report Issues
April 20th, 2021 at 10:08 AM
SEC Obtains Emergency Asset Freeze Against Actor Operating a $690 Million Ponzi Scheme
April 19th, 2021 at 9:44 AM
Read More »
Latest News
Eccleston Law Launches Search to Hire Additional Attorneys Nationwide
April 15th, 2021 at 12:37 PM
Just Saying “No” to Firm-Provided and Conflicted Legal Counsel in Your Transition may avoid problems later
April 14th, 2021 at 3:55 PM
Read More »
Share

Request a Free Consultation

Attorneys are standing by during regular business hours. Call us now for immediate service, or complete the form below and we will contact you as soon as possible.

Your E-mail Address:
 
Chicago
55 West Monroe St.
Suite 610
Chicago, Illinois 60603
(312) 332-0000
(312) 332-0003
New York City
One Liberty Plaza
165 Broadway, 23rd Floor
New York, New York 10006
(312) 332-0000
(312) 332-0003
Boca Raton
2255 Glades Road
Suite 324A
Boca Raton, Florida 33431
(312) 332-0000
(312) 332-0003
2021 © Eccleston Law, LLC.
All Rights Reserved.
The law is continuously changing. Please do not rely on information found on this site without consulting a lawyer to determine if any recent changes in the law may have an impact.