# Chief compliance officer

`kaal:entity:chief-compliance-officer`

**Status.** derived

This node is assembled mechanically from the 5 claims that carry the concept tag `chief-compliance-officer`. It is a roster of what the corpus says under this term. It is **not** an adjudicated definition: no single statement here has been ruled canonical, and no first-appearance call has been made. Read the claims and judge for yourself.

## Every claim under this term

5 claims across 4 works, 2013 to 2016.

**2013**

- [2317580-019](https://wulfkaal.github.io/claims/2317580-019) [design/evidenced] -- 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.
  > 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).
  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
- [2317580-028](https://wulfkaal.github.io/claims/2317580-028) [mechanism/argued] -- Because CIAs mandate a chief compliance officer and dictate how that officer interacts with the board, they increase the board's knowledge and monitoring of compliance, and a board possessing such knowledge should play a bigger role in ensuring that the company meets federal and state standards.
  > More specifically, because CIAs often mandate a CCO and dictate how the CCO interacts with the board, CIAs can increase boards' knowledge and monitoring of the company's compliance.
  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
- [2337268-039](https://wulfkaal.github.io/claims/2337268-039) [condition/argued] -- A chief compliance officer is effective only if he or she combines sufficient knowledge of IAA obligations with adequate authority to develop and enforce policies and procedures; knowledge without authority is insufficient.
  > The chief compliance officer should have sufficient knowledge of IAA obligations and adequate authority to develop and enforce appropriate policies and procedures.
  Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268

**2014**

- [2486570-019](https://wulfkaal.github.io/claims/2486570-019) [empirical/evidenced] -- Although 45 percent of sampled agreements required improved communication and training, only 11 percent required the entity to create the position of chief compliance officer, so the most structural compliance remedy is the rarest.
  > Only 11 percent of the N/DPAs in our sample required the creation of a chief compliance officer.
  Wulf A. Kaal, Timothy Lacine, The Effect of Deferred and Non-Prosecution Agreements on Corporate Governance Evidence from 1993-20 (2014). SSRN: https://ssrn.com/abstract=2486570

**2016**

- [2739479-013](https://wulfkaal.github.io/claims/2739479-013) [condition/evidenced] -- 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.
  > 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.
  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

Every claim above resolves to a record carrying a verbatim source quote, the sha256 of the source PDF, and a preformatted citation. Nothing here asks to be taken on trust.

    curl -s https://wulfkaal.github.io/entities/chief-compliance-officer.md | sha256sum

**Canonical form.** This markdown file is the canonical hashed representation of this entity node. Its sha256 is the content hash.