# kaal:claim:2317580-019

**Claim.** CIAs reach into the day to day compliance operations of corporations by elevating the chief compliance officer, typically mandating the appointment of a CCO who reports directly to the CEO rather than to the general counsel or chief financial officer and who has direct access to the board.

**Type.** design  **Support.** evidenced

**Holds when.**

- regulated entities operating under a comprehensive CIA

**Source quote.**

> The CCO is responsible for implementing the CIA and must generally report directly to the Chief Executive Officer (CEO), not to the General Counsel or Chief Financial Officer (CFO).

**From.** Wulf A. Kaal, Elizabeth R. Malay, *The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties* (2013), III.3 Reach and Scope, page 12

**Cite as.** Wulf A. Kaal, Elizabeth R. Malay, The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties (2013). SSRN: https://ssrn.com/abstract=2317580

**Verify.** sha256 of source PDF `50973e1e820aef47a4e7ffdbdcb513d03f1845643fcf4fa5910e9528a0b7dac2` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20and%20Malay%20-%202013%20-%20The%20Role%20of%20Corporate%20Integrity%20Agreements%20in%20the%20Expansion%20of%20Fiduciary%20Duties.pdf

**Topics.** compliance, disclosure

**Keywords.** chief-compliance-officer, reporting-lines, compliance-committee, corporate-integrity-agreements

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