The CCO of the adviser to a number of private funds, who allegedly had “a complete lack of qualifications” for the job and aided and abetted the adviser’s violations, has been ordered to disgorge half of the salary he earned as CCO. Although the dollar amounts at stake were miniscule by hedge fund standards, the enforcement action is a reminder that the SEC expects each CCO to be qualified for the role and to exercise independent judgment. This article analyzes the underlying misconduct; the enforcement action; and the terms and reasoning of the Order. The article also provides insights on hiring a qualified CCO from two former SEC officials. See “NYC Bar Report on CCO Liability Calls for More Regulatory Guidance, Transparency and Cooperation” (Mar. 5, 2020); and “HFLR Fireside Chat With SEC Commissioner Hester M. Peirce Explores Fiduciary Duty, Accredited Investor Standard and CCO Liability (Part One of Two)” (Nov. 21, 2019).