SEC Rule 206(4)-7 states that an SEC registered investment adviser’s chief compliance officer (“CCO”) should be competent and knowledgeable regarding the Investment Advisers Act of 1940 and should be empowered with full responsibility and authority to develop and enforce appropriate policies and procedures for the investment adviser. A registered investment adviser’s chief compliance officer should have a position of sufficient seniority and authority within an investment adviser’s organization to compel others to adhere to the supervisory and compliance policies and procedures. For SEC registered investment advisers, the designated chief compliance officer should be disclosed on the investment adviser’s Form ADV, Schedule A.

With respect to a state registered investment adviser, the individual designated as primarily responsible for compliance should be disclosed on Form ADV Part 1B. Similar to the SEC’s requirements of a chief compliance officer, an individual holding such a position with a state registered investment adviser should have sufficient experience, knowledge and authority to hold such a role.