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. |