SEC Chief of Staff Shares Fifteen-Step Plan for Adjusting to Compliance Responsibilities

In a keynote speech delivered last week, SEC Chief of Staff Andrew J. Donohue shared his thoughts and observations on compliance based on his extensive experience in the investment management industry, including his service at the SEC. Donohue offered advice about the role of compliance and suggested a 15-step plan for compliance personnel to adjust to ever-evolving duties. His remarks provide a valuable guide for hedge fund chief compliance officers (CCOs) as to best practices for maintaining a robust compliance program. This article highlights the key takeaways from his speech. For earlier guidance from Donohue, see “SEC Chief of Staff Offers Nine Key Considerations for Investment Adviser and Broker-Dealer Compliance Officers” (Oct. 22, 2015). For further insight from SEC officials on CCO liability, see “SEC Commissioner Speaks Out Against Trend Toward Strict Liability for Compliance Personnel” (Jun. 25, 2015); “SEC Commissioner Issues Statement Supporting Hedge Fund Manager Chief Compliance Officers” (Jul. 16, 2015); and “Commissioner Gallagher’s Dissent in SEC Enforcement Action Against Hedge Fund Manager Misses the Mark” (Jul. 30, 2015).

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