SEC Commissioner Peirce Shares Views on Personal Liability for CCOs

Regardless of whether one agrees with SEC Commissioner Hester M. Peirce’s views, there is no doubt that she has a way with words. Her speeches are always colorful and interesting, relying on relatable – and often amusing – anecdotes or analogies to explain or illustrate important points on the regulation of the financial industry. Case in point: in a recent speech, Peirce used a proverb about a nail and a horseshoe leading to the downfall of a kingdom as a jumping-off point for analyzing when CCOs should be held personally liable. This article presents the key takeaways from Peirce’s speech. For further commentary from Peirce, see our two-part coverage of the HFLR’s fireside chat featuring the Commissioner: “Fiduciary Duty, Accredited Investor Standard and CCO Liability” (Nov. 21, 2019); and “Rule Updates, Technological Change, Role of Enforcement and Hot‑Button Issues” (Dec. 5, 2019).

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