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Securities Compliance Podcast: Compliance in Context

On Episode 13 of Season 2 of the Securities Compliance Podcast: Compliance in Context, host Patrick D. Hayes welcomes in Carlo di Florio, Chief Services Officer at ACA Group and Brian Rubin, a partner and leader of the Eversheds Sutherland securities enforcement practice to discuss the issue of CCO liability and the newly proposed NSCP Firm and CCO Liability Framework. In the Headlines section, Patrick looks the recent attention and rulemaking onslaught in the private funds space and discuss cryptocurrency enforcement trends. And finally, he wraps up today’s show with another installment of History Has Your Back series where he honor the legendary Chinese workman and builder Yi Kaizhan to teach us a compliance lesson about precision.

Season 2, Episode 13 Topics:


  • Proposed Amendments to Form PF and private fund Risk Alert

  • SEC Proposed Amendments for Private Fund Advisers


  • NSCP Regulatory Advisory Committee

  • Commentary from regulators on CCO liability

  • NYCBA Framework

  • How will the Framework impact firms and firm leadership?

  • How will the Framework impact examination teams and the examination process?

  • What is the impact of the Framework on regulator enforcement?

History Has Your Back

  • Jiayuguan Pass of the Great Wall

  • The wall stabilizing brick

  • The value of precision in compliance


 “The two key principles of the framework (that you noted on the outset), impact the overall exam process. Right? So one is, I think the NSC framework does a really good job of emphasizing, taking a holistic approach to looking at the compliance program, and the culture within the firm, overall. And then two, doing so earlier in the regulatory exam or the enforcement of the investigative process.” – Carlo di Florio 

“We hope that FINRA and the SCC (and other regulators) might be able to use this Framework as a solid foundation by which to conduct parts of their investigation processes. But then again, another benefit would be for a persons (like yourself and others) that might be thinking about how to defend against an enforcement action, just to be able to show that there were other mitigating circumstances involved.” – Patrick Hayes 

Podcast Season 2 Episode 13

Listen to the full episode. 

About the Securities Compliance Podcast: Compliance in Context

Introducing the Securities Compliance Podcast: Compliance in Context presented by Calfee, Halter & Griswold and the National Society of Compliance Professionals and hosted by Patrick D. Hayes, Senior Counsel and leader of Calfee's Investment Management practice.

Designed as a personal master class for the securities legal and compliance professional, this podcast embodies Patrick’s passion to help you put Compliance In Context™ by combining the technical expertise of industry thought leaders and innovators with the practical experience of doers and key decision makers.

Listeners will find the podcast on Apple Podcast, Google Podcast, Spotify and Stitcher.

The opinions expressed by guest speakers and panelists during Securities Compliance Podcasts may not necessarily reflect the viewpoints of the attorneys and professionals of Calfee, Halter & Griswold LLP or its subsidiaries or affiliates. Calfee’s educational content is intended to inform and educate readers about legal developments and is not intended as legal advice for any specific individual or specific situation. Please consult with your attorney regarding any legal questions you may have. With regard to all content including case studies or descriptions, past outcomes do not predict future results.

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Susan M. Kurz
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