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:
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> 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:
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> 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:
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> 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:
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> 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