The old adage, “The cover up is worse than the crime,” comes to mind in two SEC settled enforcement proceedings against CCOs who provided SEC examiners with backdated documents. In the more egregious of the two matters, the CCO of an investment adviser allegedly fabricated and modified preclearance forms for personal trades, including by signing a portfolio manager’s name to the forms, and then failed to be forthright with SEC examiners when asked about the forms. In the other, another investment adviser CCO allegedly created and backdated checklists evidencing the adviser’s annual compliance reviews. This article discusses the enforcement proceedings, with lessons for CCOs from Robert W. Pommer III and Nathan R. Schuur, partners at Proskauer. See “SEC Sanctions Investment Adviser and CCO for Compliance Failures That Allowed Misappropriations” (Jul. 17, 2025).