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Behind the SEC's Recent Crackdown on Compliance Officials
Recent comments by Securities and Exchange Commission (SEC) Commissioner Daniel Gallagher were noteworthy for both their candor and the subject he raised. On June 18, 2015, Gallagher wrote in a statement placed on the SEC website (http://tinyurl.com/nnatjpw) that the SEC was sending a “troubling message”: Chief compliance officers (CCOs) should not take ownership of their firms' compliance policies and procedures, lest they be held accountable for conduct that is not really their responsibility. He explained his dissents in two recent Enforcement actions brought by the SEC against CCOs and derided as not a “model of clarity” an SEC rule that requires investment advisers to adopt and implement written policies and procedures reasonably designed to prevent violations of laws and regulations. He also expressed concern that the SEC's current approach would actually disincentivize a vigorous compliance function at investment advisers.
The Two Recent SEC Cases Referenced by Gallagher
The two recent Enforcement actions referenced by Commissioner Gallagher, who is leaving the SEC soon, are worth exploring. The first case cited involved BlackRock Advisers, a registered investment advisory firm with approximately $452 billion assets under management. According to the SEC, BlackRock first knew of and approved an investment of $50 million into the company made by Daniel Rice III, who was the general partner of Rice Energy, a family owned-and-operated oil and natural gas company; and second, a joint venture that Rice Energy later formed with a publicly traded coal company. It eventually became the largest holding (almost 10%) in the $1.7 billion BlackRock Energy & Resources Portfolio, the largest Rice-managed fund.
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