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标题: Compliance Officer Independence - Fun Fact [打印本页]

作者: adehbone    时间: 2011-7-13 16:03     标题: Compliance Officer Independence - Fun Fact

Independence for CCO is defined as (a) separate from investment personnel and (b) reports to CEO **or BOD**. Just check the CFAI books.

So it isnt just strictly CEO to determine independence. I would argue that having someone report to a BOD - or BOD like entity - enhances independence as anything the CCO finds would be aired to a larger group... Just like the CEO doesnt report to the Chairman of the Board, he/she reports to the Board.

Im just sayin.
作者: Zestt    时间: 2011-7-13 16:03

I didn't realize this was in debate?
作者: Analti_Calte    时间: 2011-7-13 16:03

Mr. Sponge - I didnt think so either but apparently there are those who think otherwise. Simpletons.
作者: liangfeng    时间: 2011-7-13 16:03

Not sure if you're confusing BOD with "investment committee", but they're not the same thing.

Just an FYI.
作者: Valores    时间: 2011-7-13 16:03

Im not confusing them - they are equivalent.
作者: skycfa    时间: 2011-7-13 16:03

charlottekid Wrote:
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> Im not confusing them - they are equivalent.


Lol..............no sir; no they are not.

Not even related to each other, save for the CEO will usually be on both.

An investment committee with be comprised of PMs and heads of trading; a board of directors will be composed of external (and internal) professionals who may or may not have experience in the firm matters.

Believe you me, they're totally different entities.
作者: bkballa    时间: 2011-7-13 16:03

If the investment committee sets the policies of the firm - its like a BOD. You can have a firm that follows AMC without a BOD... A limited partnership doesnt necessarily have a BOD... its all about who has the power @ the top.
作者: former    时间: 2011-7-13 16:03

Also - the CFAI text says the CCO should report to BOD "where possible..." Aint always possible.



Edited 1 time(s). Last edit at Friday, June 11, 2010 at 09:32AM by charlottekid.
作者: jmh530    时间: 2011-7-13 16:03

So are you saying a firm without an entity called a BOD cant have an independent CCO?
作者: oneboy    时间: 2011-7-13 16:03

BOD and investment committee not the same.
This q was a gimmie. One of the few, the proud.
作者: liangfeng    时间: 2011-7-13 16:03

I am not referring to any question on the exam, dingus.
作者: liangfeng    时间: 2011-7-13 16:03

This reading is about best practices; the clear take away is that the CCO should not report to the Investment Committee as it is a clear conflict of interest. Best practices would say CEO or BOD....that is going to cover the majority of situations.
作者: Analti_Calte    时间: 2011-7-13 16:03

Will you agree that all entities under the AMC may not have BODs?
作者: justin88    时间: 2011-7-13 16:03

charlottekid Wrote:
-------------------------------------------------------
> So are you saying a firm without an entity called
> a BOD cant have an independent CCO?


No, not at all - the CCO would simply have to report to the CEO/President to ensure his/her impartiality when dealing with issues.

Lotsa AM firms don't have BODs.
作者: liangfeng    时间: 2011-7-13 16:03

SB - but i think/thought I do understand the components.... Just that when i read about firms that employ the AMC and have a CCO but dont see any reference to a CEO or BOD in the firm, i just get a little confused....

I will repeat - apologies to Mr. B.
作者: mar350    时间: 2011-7-13 16:03

charlottekid Wrote:
-------------------------------------------------------
> SB - but i think/thought I do understand the
> components.... Just that when i read about firms
> that employ the AMC and have a CCO but dont see
> any reference to a CEO or BOD in the firm, i just
> get a little confused....
>
> I will repeat - apologies to Mr. B.

It's Ms. B, but I doubt she took too much offense.
作者: IAmNeil    时间: 2011-7-13 16:03

No worries.
作者: mcmc    时间: 2011-7-13 16:03

Oops. Now i really feel stupid. But I should feel just as stupid -- right? Shouldnt discriminate...
作者: Darien    时间: 2011-7-13 16:03

Not sure. Sounds offensive though, right?

I made it up out of frustration with my performance Saturday. Or lack thereof.

Feel like every q I wrestled with (whether or not most others did) I ended up landing in the quicksand.

Im not happy that Skill clearly disagrees with me. Does not bode well for me.

Peace out.
作者: liangfeng    时间: 2011-7-13 16:03

charlottekid Wrote:
-------------------------------------------------------
> Not sure. Sounds offensive though, right?
>
> I made it up out of frustration with my
> performance Saturday. Or lack thereof.
>
> Feel like every q I wrestled with (whether or not
> most others did) I ended up landing in the
> quicksand.
>
> Im not happy that Skill clearly disagrees with me.
> Does not bode well for me.
>
> Peace out.


Please don't jinx me like that, but good luck to you.
作者: canadiananalyst    时间: 2011-7-13 16:03

My bad -- I am sure you did fine. Good luck to you and the Madame Banni.

I will now continue to lurk.... But be careful... i will be watching.
作者: aidebaobao    时间: 2011-7-13 16:03

Sponge_Bob_CFA Wrote:
-------------------------------------------------------
> WTF is a dingus anyway?

n. {Slang} An article whose name is unknown or forgotten.
A person regarded as stupid.
作者: Analti_Calte    时间: 2011-7-13 16:03

great. now im on the hook for plagiarism.




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