SEC Commissioner Peirce Shares Views on Personal Liability for CCOs

A missing nail from a horseshoe is a seemingly small problem, but it can trigger the downfall of an entire kingdom, SEC Commissioner Hester M. Peirce explained in a recent speech, likening the nail and horseshoe proverb to how certain acts or omissions can lead to personal liability for CCOs. “Who should be held responsible for that fallen nail?” she asked. We highlight the takeaways from Peirce’s colorful speech about the boundaries of CCO liability. See “Report on CCO Liability Calls for More Regulatory Cooperation” (Apr. 15, 2020).

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