Category: Articles & Publications

Alaric’s Response to the SEC Alert on Outsourcing of CCOs

SEC Observations and Alaric Practices: Outsourcing the Role of the Chief Compliance Officer

Monday, November 9, 2015 — the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert regarding the Examinations of Advisers and Funds that outsource their Chief Compliance Officers. In the Risk Alert, the SEC affirmed that registered investment advisers and registered investment companies can outsource the Chief Compliance Officer (“CCO”) role to a third-party.

However, OCIE emphasized that it remains the adviser or funds’ responsibility to adopt and implement an
effective compliance program, and to be comfortable that the CCO has the sufficient knowledge, support and experience to fulfill the responsibilities associated with the applicable compliance rules and regulations and to be aware of the risks should this not be the case.

At Alaric Compliance Services, LLC (“Alaric”), we believe that outsourcing the role of CCO, if done
correctly, can bring many benefits to an adviser or fund registered with the SEC, FINRA and/or the NFA/CFTC…

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