Compliance Officer Independence - Fun Fact anything, determine, investment

adehbone

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.

Zestt

I didn't realize this was in debate?

Analti_Calte

Mr. Sponge - I didnt think so either but apparently there are those who think otherwise. Simpletons.

liangfeng

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

Just an FYI.

Valores

Im not confusing them - they are equivalent.

skycfa

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.

bkballa

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.

former

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.

jmh530

So are you saying a firm without an entity called a BOD cant have an independent CCO?

oneboy

BOD and investment committee not the same.
This q was a gimmie. One of the few, the proud.