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Meaghan Kelly Quoted in Regulatory Compliance Watch on CCO Best Practices in Correspondence with SEC Examiners
10.28.21
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Litigation Partner Meaghan Kelly was quoted in a Regulatory Compliance Watch article titled, “CCOs Signing SEC Correspondence.” The article addresses best practices for investment adviser CCOs engaging with SEC examiners, including with respect to ways that CCOs can mitigate liability risks when signing a firm’s response to a deficiency letter, especially if an SEC exam is heading towards possible enforcement. Meaghan noted that, “It’s very, very important for a CCO to stand behind a firm’s compliance program, including any deficiency letter response.” She additionally highlighted that a CCO’s best form of protection is oversight of a functional compliance program with the appropriate resources and access to senior management and outside experts.
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