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The Investment Lawyer Publishes Second Segment of Supervisory Liability Article by O'Melveny's Traeger, JimboMarch 28, 2014
The April 2014 issue of The Investment Lawyer includes the second installment of a two-part article written by O'Melveny & Myers partner Heather Traeger and associate McAllister Jimbo, titled “Supervisory Liability: The SEC's Scrutiny and Support of Chief Compliance Officers." The second segment discusses areas to consider when assessing potential liabilities and suggests steps compliance officers can take in order to minimize potential liability. “To minimize their liability risk, CCOs should consider the SEC's policy goals and take appropriate steps to ensure they are promoting a culture of compliance at their firms, while also limiting their exposure to personal liability,” the authors write, adding that “CCOs who serve as in-house lawyers should keep in mind their ethical obligations, especially in relation to client confidentiality and disclosure of potential violations by their employers.”
Traeger is a member of O’Melveny’s Financial Services Practice and Jimbo is a member of the Litigation Department. They reside in the Firm’s Washington, DC office.