Patrick D. Hayes, Calfee's Investment Management Practice Group Chair and National Society of Compliance Professionals (NSCP) Board Member, co-authored an updated version of the NSCP Firm and CCO Liability Framework ("NSCP Framework"), as announced in a news release yesterday by the NSCP. The NSCP Framework seeks to alleviate regulatory uncertainty faced by certain chief compliance officers (CCOs), provide a framework consistent with the industry's perception of the role of compliance, and promote investor protection and market integrity.
Patrick is quoted in the news release as stating, "The Framework has been used by many firms and CCOs to assess the compliance function within their organizations. This update will provide additional guidance to help firms focus their compliance efforts and empower CCOs managing the compliance program."
The original NSCP Framework was issued in January 2022 because many of its CCO and other financial industry members perceived the need to provide guidance to regulators and others regarding potential CCO liability. Since that time, Patrick Hayes and other members of the NSCP's Regulatory Advisory Committee have met with various regulators from the U.S. Securities and Exchange Commission, FINRA, and other industry professionals to gather feedback as they developed these updates.
NSCP is the premier organization that educates and advocates on behalf of financial industry compliance professionals.
Read the full news release from the NSCP here: https://www.nscp.org/news-main/nscp-releases-revised-nscp-firm-and-cco-liability-framework.