Every PE sponsor operates with different objectives, resources and personnel, so logically, the challenges faced by CCOs differ across the industry. Nonetheless, all PE sponsors are confronting the onslaught of SEC rulemaking of late and trying to discern the best way to leverage their resources to be prepared. In that case, it can be helpful to hear what steps CCOs from other PE sponsors are taking so that anecdotal lessons and tips can be applied. Those were addressed at the Investment Company Institute (ICI) 2022 Investment Management Conference in a panel moderated by Tamara Salmon, ICI’s associate GC, which featured several CCOs, including Brian Harris from State Street Global Advisers, Michael F. Hogan from Charles Schwab Investment Management Inc. and Christina E. Sears from American Beacon Funds. The program also featured Peter Driscoll, PwC partner and former Director of the SEC’s Division of Examinations. This first article in a two-part series contains useful anecdotes from CCOs about ways they are allocating their resources to manage challenges from the recent proliferation of SEC rules and amendments. The second article
will relay the CCOs’ thoughts on the evolving approach of the SEC’s Division of Enforcement; what they expect from the SEC going forward; trends as to CCO liability; and the handling of environmental, social and governance issues. For coverage of a previous ICI panel, see “SEC Examinations and Enforcement Officials Discuss Key Regulatory Issues for Investment Advisers
” (May 18, 2021).