The CCOs of private fund managers have a lot of responsibility. Ensuring the adequacy of managers’ compliance programs largely falls on their shoulders; thus, they are under tremendous pressure. Increased SEC focus on holding individuals accountable for securities violations has stoked fears among CCOs of being held personally liable for their firms’ compliance failures. Those fears are only enhanced when CCOs lack the support and resources needed to ensure compliance with an evolving regulatory landscape. The reality is that CCOs – particularly of smaller firms – continue to struggle to obtain sufficient resources to perform core compliance duties. Bottom line: CCOs need all the help they can get. See “Personal Liability and Compliance Resourcing Are Top Concerns Among CCOs, Surveys Show
” (Jan. 13, 2022). In the spirit of trying to lighten the load of CCOs – and in light of the upcoming July 4th holiday in the U.S. – the Hedge Fund Law Report is highlighting five articles that include checklists that CCOs can adapt and use to evaluate their employee disciplinary policies and procedures; streamline their annual compliance reviews; prepare traders for interviews during SEC exams; preclear employees’ personal trading to avoid violating the pay to play rule; and ensure adequate vendor management.