Hiring a dedicated chief compliance officer (CCO) requires both an expansive and focused search; although a fund manager would ideally hire someone who possesses competencies that match closely with its activities, it may not have that luxury depending on the pool of qualified candidates. Once a manager has hired a CCO, it should properly onboard him or her and develop a governance structure specific to its values and culture. Although the U.S. government tends to prefer separation between an organization’s compliance and legal departments, a priori
departmentalization may lead to several unintended consequences. A manager must not stop once the CCO has been hired and onboarded, however; managers must understand and be prepared for the attendant risks of CCO turnover, such as the breakdown of day-to-day responsibilities. This article, the second in a three-part series, examines CCO hiring and onboarding; explores whether managers should separate their compliance departments from their legal departments; and analyzes the risks of high CCO turnover. The first article
discussed the SEC’s proposed rule on business continuity and transition plans; the potential impact of the rule’s withdrawal; the importance of CCO succession planning; and the risks of using an outsourced CCO. The third article
will evaluate the risks of poor succession planning and provide a roadmap for developing a robust succession plan. See “Survey Reveals Compliance Weaknesses of Hedge Fund Managers Relative to Other Financial Services Firms, Including CCO Qualifications and Frequency of Annual Compliance Reviews
” (Sep. 15, 2016).