Partner Paul Lieberman Quoted In ACA Article Regarding Best Practices For CCO’s.
June 12, 2015
Scarinci Hollebneck Partner Paul A. Lieberman was quoted in the May 15, 2015 edition of the ACA Compliance Group Insight’s article “Chief Compliance Offers Best Practice For Self-Protection.”
The focus of the article was on “nightmare scenarios” frequently faced by CCO’s in performing their functions, including possible regulatory sanctions.
Mr. Lieberman, who is a frequent contributor to the ACA on SEC, FINRA and state regulatory compliance matters, offered his view on “best practices” to be followed by CCO’s who have uncovered violations within their firm.
He is quoted extensively in an article that discusses the following topics
- Report up
- Create and keep written records
- Make a detailed written report
- Does a CCO need third-party help in convincing upper management or self-reporting to the SEC?