One of the things that keeps CCOs up at night is the prospect of being held personally accountable for a firm’s compliance failures. CCO liability has also been the subject of considerable debate within the SEC, and FINRA recently weighed in on the subject in recently released Regulatory Notice 22‑10 (Notice). The Notice outlines the circumstances in which a CCO may be held liable for violating FINRA Rule 3110 (Rule), which sets forth a firm’s supervisory obligations, including the factors mitigating for and against formal charges under the Rule. This article discusses the key takeaways from the Notice, with commentary from W. Hardy Callcott and Lara C. Thyagarajan, partners at Sidley Austin. See “A Look at the NSCP’s Firm and CCO Liability Framework” (Feb. 24, 2022); and our two-part series on the NYC Bar framework for CCO liability: “Components and Proposals” (Jul. 15, 2021); and “CCO and Regulator Perspectives” (Jul. 22, 2021). See also “How CCOs Can Avoid Personal Liability for Organizations’ Compliance Failures” (Mar. 11, 2021).