A chief compliance officer (“CCO”) for a registered investment adviser (“RIA”) found himself barred from any compliance or supervisory role in the future because he willfully refused to fix a number of compliance issues.  See https://www.sec.gov/litigation/admin/2017/34-82397.pdf. 

The RIA had conducted a review that uncovered numerous compliance problems.  Despite having notice of the results of this review, the CCO simply ignored it, and did not address any of the problems, including, among other things, the failure to retain emails, electronic information, or protect customer information.  The CCO also failed to update the compliance manual or conduct an annual review.

Such a step by the SEC is in keeping with its belief that CCOs are on the front lines of ensuring that the public are protected.  Here, it seems that the CCO ignored those responsibilities, and was punished severely.

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