# kaal:claim:2739479-013

**Claim.** Firms that outsource the chief compliance officer role to third parties face heightened SEC scrutiny and examination risk, and the SEC has signaled that CCO liability arises where CCOs mislead regulators, engage in affirmative misconduct, or fail to carry out assigned compliance responsibilities.

**Type.** condition  **Support.** evidenced

**Holds when.**

- SEC-registered advisers and funds
- since 2015

**Source quote.**

> Firms that outsource their chief compliance roles to third parties face increased scru- tiny and threat of examination.131 The SEC warns that CCO liability could be- come an issue if CCOs mislead regulators, engage in affirmative misconduct, or fail to carry out compliance responsibilities.

**From.** Wulf A. Kaal, *The Post Dodd-Frank Act Evolution of the Private Fund Industry Comparative Evidence from 2012 and 2* (2016), II.2. Regulatory Developments, page 21

**Cite as.** Wulf A. Kaal, The Post Dodd-Frank Act Evolution of the Private Fund Industry Comparative Evidence from 2012 and 2 (2016). SSRN: https://ssrn.com/abstract=2739479

**Verify.** sha256 of source PDF `b2e7b81a16ab01c73478b62e85068f9dadc5cdd18427241e8bc5e8216a967730` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20-%202016%20-%20The%20Post%20Dodd-Frank%20Act%20Evolution%20of%20the%20Private%20Fund%20Industry%20Comparative%20Evidence%20from%202012%20and%202.pdf

**Topics.** compliance, law-and-legal-systems, securities-law

**Keywords.** chief-compliance-officer, cco-liability, sec-examinations, outsourced-compliance, enforcement

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