The position of chief compliance officer of a registered investment adviser has always carried with it the risk of personal liability. Being an outsourced CCO is even more perilous. After all, if you are not on-site at the advisory firm on a daily basis, you are going to be hard-pressed to know everything you need to in order to do your job effectively. In a recent administrative action, the SEC lowered the boom on an outsourced CCO for not taking sufficient steps to ascertain the accuracy of certain information (in this case, the firm’s reported AUM).
Whether or not you are an outsourced CCO, the case is well worth reading. You can find it here.