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Securities Compliance Podcast: Compliance in Context

The Securities Compliance Podcast S5:E2 - The CCO's Toolkit

In Season 5 Episode 2 of The Securities Compliance Podcast: Compliance in Context, host and Calfee Partner Patrick D. Hayes welcomes Rob Tull, who discusses what’s in the complete toolkit every CCO needs to build an effective compliance program. In the Headlines section, Patrick reviews recent comments from the SEC’s Enforcement Division responding to criticisms from the crypto industry. The show wraps up with an installment of Outtakes with a discussion of the first-of-its-kind enforcement action against investment advisers for misleading statements about their use of artificial intelligence.



SEC Division of Enforcement Director Gurbir S. Grewal responded to criticisms by the crypto industry challenging the agency’s authority and motivations regarding the treatment of cryptoassets.

Interview with Rob Tull

  • What’s the complete CCO toolkit needed to build an effective compliance program?
  • What skills help make a great CCO?
  • Simple steps CCOs can take to improve detection of issues.
  • How can you enhance your ability to communicate and process information?
  • What can I do to help ensure my firm empowers me in my role as CCO?
  • What are some best practices to maximize the resources I have available?
  • How understanding the firm’s strategic plan can significantly help your compliance program and your role as CCO.

Final Segment – Outtakes

SEC settled charges against two investment advisers for making false and misleading statements about their use of artificial intelligence in a first-of-its-kind enforcement action.


11:58 – “So if I had to stack these things in priority, the first thing is, do I know the rules? Am I knowledgeable? So is a compliance officer knowledgeable? That’s kind of, it’s rough. There are layers to that. The first thing is, do you know the regs that apply to your business? And that’s where there’s a ton of content from NSCP, from law firms, from consulting firms – like, we get that, we get the knowledge. But then there’s two layers on top of that. Then there’s also, do you know the industry you’re in? Like, it’s one thing to know the rules, but do you know what’s going on in the industry? What’s happening for investment managers and broker-dealers in aggregate? And then what’s happening in your business? You need to know your business. And that’s kind of the foundation, that knowledge piece.” – Rob Tull

20:29 – “The beauty about empowerment is we tend to think, once I’m the named CCO, I am, by default, empowered. That’s the way we tend to get because the rules are title-focused, we get title-focused. But what we forget is that title has nothing to do other than who gets to wear the target. What it really talks to in our ability to be empowered is our ability to demonstrate – it’s how well we demonstrate our competence and our knowledge. And it’s not an ivory tower task. It is a ‘what do you bring to the business as a value-add, to take compliance from a checklist to make it something that is additive to the business.' And that is the most important thing. And it’s not just – and this is beyond the concept of profitability, beyond that concept – it is how do you make the organization better, top to bottom.” – Rob Tull

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, Partner and Chair 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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216.622.8346 (office)
513.502.8950 (mobile)

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