Outside CounselLinda Riefberg and Joseph Dever , New York Law Journal
Compliance Officers Beware: A Firm's Failure Can Get Personal
Linda Riefberg and Joseph Dever write that the SEC and FINRA currently have different approaches to Compliance Officers. The SEC requires as a threshold matter supervisory responsibility over other individuals. FINRA, on the other hand, is satisfied if the compliance professional has supervisory responsibilities over businesses or program areas that had failures, even if the person was not an actual supervisor.