What Fund Managers Should Consider When Hiring and Onboarding CCOs; Determining CCO Governance Structures (Part Two of Three)

Hiring a dedicated CCO requires both an expansive and focused search. Although a fund manager would ideally hire someone who possesses competencies that closely match the role, it may not have that luxury depending on the pool of qualified candidates. Once a manager has hired a CCO, it should properly onboard him or her and develop a governance structure specific to its values and culture. Further, when considering its governance structure, a fund manager should weigh potential unintended consequences of the a priori departmentalization of its compliance and legal departments. This second article in a three-part series examines CCO hiring and onboarding, and it explores whether managers should separate their compliance departments from their legal departments. The first article discussed the importance of CCO succession planning; the risks of using an outsourced CCO; and issues resulting from high CCO turnover. The third article will evaluate problems that can result from poor succession planning and provide a roadmap for developing a robust succession plan. See “Survey Reveals Compliance Weaknesses of Fund Managers Relative to Other Financial Services Firms, Including CCO Qualifications and Frequency of Annual Compliance Reviews” (Sep. 15, 2016).

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