Welcome back to The Securities Compliance Podcast. In today’s special episode, we welcome in SEC Commissioner Hester M. Peirce for an in-depth conversation focusing on the controversial topic of Chief Compliance Officer (CCO) liability. In addition, we discuss the role of outsourced CCOs, the new Marketing Rule, and broker-dealer custody of digital asset securities and cryptocurrencies. She also spoke about the new presidential administration, which will bring in a new SEC Chair and Head of Enforcement, and whether she anticipates a slowdown in dialogue that’s taken place between the regulators and the industry.
Interview
Discussing the motivation to help move the conversation on CCO liability forward
Biggest takeaway from the NSCP CCO Liability survey
Concerns over whether personal liability will be imposed in cases of simple negligence
Thoughts on outsourced Chief Compliance Officers
Discussing the impact of a new Administration, SEC Chair, and Head of Enforcement
Thoughts on the new SEC Marketing Rule including key takeaways
Review the SEC request allowing limited purpose BDs to custody “digital asset securities”
Focus areas for Commissioner Peirce in 2021
Career advice for new compliance professionals
Quotes:
“And I think the compliance people at a firm play a really important role in being a bridge and saying to the operational people at the firm, the people who are providing the advice, or doing the day-