CCOs in the Cross-Hairs: Recent Developments in the Regulation of Financial Industry Chief Compliance Officers

By Barry R. Temkin and Michelle Atlas* Following the financial crisis of 2008, the role of Chief Compliance Officer for financial institutions has been redefined, most notably by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. A review of recent regulatory enforcement actions reveals a trend of increased scrutiny of Chief Compliance Officers of futures commission merchants, investment advisors, broker-dealers, and other financial services entities. It is difficult to predict how much the regulatory environment will relax under the Trump Administration. Donald Trump has announced an intention to repeal Dodd-Frank, as well as other signature Obama initiatives. Moreover, Mary Jo White, the aggressive, proenforcement chair of the Securities and Exchange Commission, has departed, leaving multiple vacancies on the commission.

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