A Look at the NSCP’s Firm and CCO Liability Framework

CCOs are concerned that regulators may be quick to impose personal liability without recognition that they are acting in good faith in a high-volume, high-pressure environment. In response to those concerns, the NSCP recently released a Firm and CCO Liability Framework (NSCP Framework). This article explains how the NSCP Framework was created, discusses its core and goals, and compares it to the New York City Bar Association’s CCO liability framework, with commentary from Genna N. Garver, a partner at Troutman Pepper and member of the NSCP’s Regulatory Advisory Committee. See “Personal Liability and Compliance Resourcing Are Top Concerns Among CCOs, Surveys Show” (Jan. 26, 2022).

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