While we could probably list dozens of attributes that an effective chief compliance officer SHOULD have, we have come up with 7 that they MUST have. An informal survey of CCOs revealed that the very the first attribute – a keen understanding of the regulatory landscape – has consistently been the most difficult to master.
- Have a keen understanding of the regulatory landscape (i.e., best practices, rule changes, red flags, proposed rule changes; examination trends).
- Have complete familiarity with the company’s compliance policies and procedures (i.e., compliance is not just one among many responsibilities).
- Have detailed knowledge of the company’s business, customer-base, operations and personnel (i.e., know where the risks are).
- Have the ability to foster a culture of compliance.
- Have an understanding of how the company uses technology and any resultant vulnerabilities.
- Have the skill-set to supervise all aspects of the company’s compliance program, including the annual risk assessment, annual review and compliance testing.
- Have the courage to speak truth to power (i.e., have the ability to tell the founder that they cannot cut corners).