Derivatives industry chief compliance officers (CCOs) are allowed to confer with senior managers at their firm - not just with chief executive officers and board members - Commodity Futures Trading Commission staff clarified. CCOs, especially
at larger firms where swap dealing isn't a major part of their business, can benefit from having a bigger pool of managers with whom to discuss compliance issues.
In addition to directors and chief executives, other senior managers in a firm with relevant experience "are likely to provide meaningful insights and assistance" to CCOs.
Under the Commodity Exchange Act (CEA), CCOs of swap dealers, futures commission merchants and major swap participants are required to report directly to the board or to the firm's senior officer and to meet with either the CEO or the board at least once a year.