SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs
Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding transparency during regulatory examinations . While the cases differ in detail, both focus on allegations that the CCO provided misleading information to regulators during an exam—highlighting one of the principal ways that individual liability can arise. Typically, CCOs are given the benefit of the doubt, but can face personal exposure when they (1) participate in the underlying misconduct, (2) fail entirely in their compliance duties, or (3) mislead regulators. These recent actions illustrate the third category. Case Summary: RIA Chief Compliance Officer Backdated and Fabricated Pre-Clearance Forms In July 2025, the SEC settled charges with the CCO of a formerly registered investment adviser for altering approximately 170 pre-clearance trading f...