A DEFICIENCY LETTER TO (NOT FROM) THE SEC: PLEASE PROVIDE MORE TRANSPARENCY WHEN CHARGING A CHIEF COMPLIANCE OFFICER WITH PERSONAL LIABILITY

Its time to send a deficiency letter to the SEC — the agency needs to do a better job of providing transparency when issuing an enforcement action against a compliance officer. See my latest post on the NYU Program on Corporate Compliance & Enforcement Blog.   Link is below:

A Deficiency Letter to (Not From) The SEC: Please Provide More Transparency When Charging a Chief Compliance Officer With Personal Liability