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As part of an ongoing and potentially far‐reaching overhaul of investment company and investment adviser regulation, the Securities and Exchange Commission recently adopted Rule 206 (4)‐7 under the Investment Advisers Act of 1940 and Rule 38a‐1 under the Investment Company Act of 1940. These new rules require each fund and adviser to implement written compliance policies and procedures and to appoint a chief compliance officer (CCO) to administer those policies and procedures. While funds and advisers have until October 5, 2004 to comply with the new rules, the breadth of those rules requires a concerted, early effort to implement the new requirements successfully by that date. This article summarizes the requirements of the new rules, focusing on the CCO requirement, and addresses the following issues that advisers and fund boards will confront (among many others) in recruiting and appointing a CCO: (i) the source of the CCO’s compensation, (ii) potential supervisory liability of a CCO, (iii) outsourcing the position of CCO, and (iv) the desired qualifications of a CCO.

This paper sets out to assess the role of the chief compliance officer (“CCO”), how the CCO performs his/her duties, and how the CCO interacts with the fund's board three years after the adoption of Rule 38a‐1 under the Investment Company Act of 1940.

Reviews the CCO's responsibilities under Rule 38a‐1, discusses how the CCO role has evolved since the rule was promulgated, and focuses on key issues such as oversight versus supervision, the annual review process, risk assessement, testing methodologies, and the annual report to the fund board on the adequacy and operation of the fund's compliance program.

Properly conducted compliance requires the support of a wide range of the advisory/administrative team with the CCO playing the role of conductor of the orchestra. More and more CCOs seek to distance themselves from approving the day‐to‐day actions of other employees, so they cannot be considered to have assumed supervisory responsibility for those employees. Although a fund is required to perform an annual review of the adequacy of its compliance programs and its Primary Service Providers' compliance programs, most CCOs have found the review process is ongoing and occurs continuously throughout the year. Now that these compliance programs have been in place for two years, more CCOs are devoting time and resources to identify high‐risk areas and to implement transactional, periodic, and forensic testing programs. The CCO annual report has taken many different shapes and sizes, but generally summarizes material changes to the fund's compliance policies and procedures that have already been reported to the board.

A current, practical assessment of the CCO role by expert lawyers who advise funds on their compliance programs.

This paper aims to discuss some of the more significant conflicts that a chief compliance officer (“CCO”) may face in implementing a compliance program and to offer suggestions intended to reduce the conflicts and strengthen the advisory firm's compliance program.

Discusses the CCO's degree of independence from the financial adviser, identifies the areas where conflicts of interest most frequently arise, and provides advice on managing potential conflicts.

Potential conflict‐of‐interest problem areas include security valuation, trade allocations, affiliated transactions between the firm and its clients or among the firm's clients, soft dollar transactions, investment performance reporting, and personal trading activities of investment personnel. The CCO should work with the advisory firm's senior management to identify potential violations of the firm's compliance program and establish disciplinary actions as well as escalation procedures for compliance violations. Conflicts can be reduced if the CCO reports to the board of directors of the advisory firm or that firm's parent. The CCO review process should be handled by someone other than an officer whom the CCO monitors. The CCO should seek independent outside sources to help identify and resolve compliance issues.

Provides a guide to potential conflicts of interest from a lawyer who advises investment funds and investment advisers.

Studies that inquire in-depth into whether the Corporate Communications Officer (CCO) is an entrusted corporate executive and enacts a genuine leadership of his/her own style are generally neglected. The purpose of this paper is to unravel the leadership nature of the CCO beyond the managerial role. More specifically, the authors collected accounts of the span of the professional life and job experiences of CCOs, with the aim of understanding how their leadership, if any, can be depicted.

The authors developed a qualitative research design to grasp the complexity of the CCO job experience. The authors chose a narrative approach involving a purposive sample of CCOs operating in global companies based in Italy to elicit and nurture their spontaneous reconstruction of the significant moments of their working lives.

Based on the interpretive analysis, the capability of the CCO to overcome the trap of the formal appointment seems to rely on the organic emergence of a genuine leadership. The turning point between his/her resting on the appointment or becoming a genuine leader is marked by the display of his/her humanistic nature that can be ascribed to the enactment of a conversational leadership.

While this is an exploratory qualitative study, it holds heuristic value in deepening the specific nature of genuine CCO leadership beyond an essentially task-based analysis of its managerial profile.

This paper articulates the significant value of the role of the Chief Customer Officer, namely in the CCO's ability to create and leverage customer strategy.

The paper offers a view of the evolution of the CCO over six years based on recently completed in‐depth interviews with more than 50 CCOs at Fortune 500, mid‐cap, and smaller companies.

The article describes the three most common reasons why CEOs hire Chief Customer Officers. The CCO role is evolving and rapidly increasing in complexity, defying simple categorization that was possible six years ago. CCOs can be classified in two dimensions according to their customer accountability and the organizational authority of their role. CCOs share three common goals: drive profitable customer behavior, create a customer‐centric culture, and driver corporate and customer strategy. Also discussed are the most critical factors that must be in place to ensure CCO success.

While the sample size of 50 out of 300 is representative, the CCO role is evolving quickly and is adapted as necessary within each company to fit the specific organizational needs.

The majority of the material is new. This research begins to codify the most critical factors in the CCO role to provide structure for CEOs and Boards considering installing a CCO. CCOs should evaluate their key performance indicators to ensure they are tied to profitability so as to better justify and defend their value. Growth companies must bear in mind the need to migrate the CCO from line ownership to process ownership to properly manage complexity.

The purpose of this study is to empirically examine the impact of cosmopolitan consumer orientation (CCO) on sustainable apparel consumer behavior.

A total of 469 US responses collected using MTurk were retained for the analysis after screening for unengaged responses. Structural equation modeling was used to confirm the factor structure of the measurement model and to analyze the structural model. A two-step cluster analysis using log-likelihood distance measure and Akaike's Information Criterion was conducted to explore consumer profiles and past behavior.

Based on the model results, CCO positively impacts apparel sustainability knowledge, attitude toward purchasing sustainable apparel, perceived norm and sustainable apparel purchase intention. Attitude and perceived norm also impact sustainable purchase intention. The two-step cluster analysis, based mainly on sustainable past behavior, reveals that the group of sustainability engaged consumers knows more about apparel sustainability, has a stronger intention to purchase sustainable apparel, is more cosmopolitan and shows a higher tendency to follow social norms. Consumers in this group also tend to live in metropolitan areas and are slightly younger than unengaged consumers.

This study expands CCO research linking two major trends in society and industry: cosmopolitanism and sustainable apparel consumer behavior. The study reveals that CCO uplifts consumers' sustainable behavior and provides evidence in support of CCO as a driver of sustainable consumer behavior. Moreover, results imply a positive future outlook for the diffusion of sustainable apparel, as well as a much-needed mainstream consumer adhesion to more sustainable lifestyles. Given the repercussions of the findings, this research has numerous theoretical as well practical implications.

Extant research on corporate social responsibility (CSR) communication primarily relies on a transmission model of communication that treats organizations and communication as distinct phenomena. This approach has been criticized for neglecting the formative role of communication in the emergence of organizations. This paper seeks to propose to reconceptualize CSR communication by drawing on the “communication constitutes organizations” (CCO) perspective.

This is a conceptual paper that explores the implications of switching from an instrumental to a constitutive notion of communication.

The study brings forth four main findings: from the CCO view, organizations are constituted by several, partly dissonant, and potentially contradictory communicative practices. From that viewpoint, the potential impact of CSR communication becomes a matter of connectivity of CSR to other practices of organizational communication. Communication practices that concern CSR should not be generally dismissed as mere “greenwashing” – given that some forms of talk can be action. Consequently, there is a need to investigate which specific speech acts create accountability and commitment in the context of CSR. The CCO view shows that CSR communication potentially extends the boundary of the organization through the involvement of third parties. Thus, it is fruitful to study CSR communication as a set of practices that aims at boundary maintenance and extension. Organizations are stabilized by various non‐human entities that “act” on their behalf. Accordingly, CSR communication should also take into account non‐human agency and responsibility.

This paper links the literature on CSR communication to broader debates in organizational communication studies and, in particular, to the CCO perspective. By applying the CCO view, it reconceptualizes CSR communication as a complex process of meaning negotiation.

A performance management system has been implemented by Cancer Care Ontario (CCO). This system allows for the monitoring and management of 11 integrated cancer programs (ICPs) across the Province of Ontario. The system comprises of four elements: reporting frequency, reporting requirements, review meetings and accountability and continuous improvement activities. CCO and the ICPs have recently completed quarterly performance review exercises for the last two quarters of the fiscal year 2004‐2005. The purpose of this paper is to address some of the key lessons learned.

The paper provides an outline of the CCO performance management system.

These lessons included: data must be valid and reliable; performance management requires commitments from both parties in the performance review exercises; streamlining performance reporting is beneficial; technology infrastructure which allows for cohesive management of data is vital for a sustainable performance management system; performance indicators need to stand up to scrutiny by both parties; and providing comparative data across the province is valuable. Critical success factors which would help to ensure a successful performance management system include: corporate engagement from various parts of an organization in the review exercises; desire to focus on performance improvement and avoidance of blaming; and strong data management systems.

The performance management system is a practical and sustainable system that allows for performance improvement of cancer care services. It can be a vital tool to enhance accountability within the health care system.

The paper demonstrates that the performance management system supports accountability in the cancer care system for Ontario, and reflects the principles of the provincial governments commitment to continuous improvement of healthcare.

This article explores the methods and benefits of creating an executive‐level position accountable for maintaining and enhancing the value of the customer base as an asset. This position is referred to as chief customer officer (CCO). The article is based on the author’s recent study of companies with a CCO, including Sun Microsystems, Cisco, Hewlett‐Packard, Unica, Monster.com, Fidelity, The MathWorks, and others. The study was conducted using personal and telephone interviews with executives with the defined function, whatever their actual title. The interviews were supplemented with documentary material. The CCO, by whatever title he or she may go, uses various methods to continually gather customer insight, to disseminate that insight throughout the organization, and to drive change so that the organization consistently meets customer needs quickly and profitably. To do this, a CCO needs sufficient authority and respect across divisions and functions, and needs to be held accountable for measurable results (although they may not be the familiar metrics). Three types of CCO are the generalist, the service‐revenue driver, and champions by committee. This article addresses executives in companies frustrated by declining prices and margins, decaying sales, lackluster market performance, and unprofitable customers. Such problems reflect a lack of customer insight, or of ability to act on it, and call for the creation of a CCO role specifically tasked with gathering such insight and using it to drive company change and initiative.

This paper summarizes the requirements of rule amendments promulgated by the Commodity Futures Trading Commission (CFTC) in 2018 regarding the duties of Chief Compliance Officers (CCOs) of swap dealers, major swap participants, and futures commission merchants (collectively, Registrants) and the requirements for preparing, certifying and furnishing to the CFTC the CCO’s annual report.

This paper provides a close analysis of the CFTC’s final rule amendments that make clarifications regarding the CCO’s duties and seek to harmonize with similar rules of the Securities and Exchange Commission (SEC) applicable to security-based swap dealers.It also analyzes rule amendments for the CCO’s report that provide clarifications and simplify certain requirements.In each case, it discusses comments from the public and the CFTC’s responses to those comments.

This paper finds that the rule amendments provide a number of helpful clarifications and simplify certain existing requirements for Registrants and their CCOs subject to the rules.While the rules overall achieve greater harmonization with similar rules of the SEC governing CCOs of security-based swap dealers, this paper notes that care will need to be taken by CFTC Registrants who also become registered with the SEC to be cognizant of remaining differences between the CFTC’s and SEC’s rules in order to ensure compliance with the rules of each agency.

This paper provides valuable information regarding the duties of CCOs of Registrants and CCO annual report requirements from an experienced lawyer focused on commodities, futures, derivatives, energy, corporate, and securities regulatory matters.