Although the US Securities and Exchange Commission (SEC) and its staff members have issued informal guidance on when a chief compliance officer (CCO) could be held personally liable for a compliance failure, uncertainty remains—compounded by the often-limited information provided in SEC settlement orders.
Hedge Fund Law Report looks at a recently settled enforcement proceeding against Hamilton Investment Counsel and its CCO and Commissioner Hester Peirce’s statement on the resolution. Partners Lance Dial, Christine Lombardo, and Kelly Gibson offer commentary on the alleged compliance failures, the terms of the resolutions, and Peirce’s observations.
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