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Data on the reporting lines of chief compliance officers

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The Society of Corporate Compliance and Ethics surveyed its members in 2009. According to a summary of the findings by John Soriano in Compliance Week, the survey found a plurality (45%) of chief compliance officers reported directly to the CEO. Only 17 percent of the respondents reported to the chief legal officer (See my post of Jan. 20, 2009: reporting lines of compliance function with 11 references.).

Nearly three quarters of the respondents believe that they should report directly to the CEO. It doesn’t surprise me that such a high percentage of believe they should report to the top executive – don’t all functional heads believe that?

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One response to “Data on the reporting lines of chief compliance officers”

  1. Stephen Nagin says:
    July 7, 2010 at 9:20 pm

    Inasmuch as compliance predominantly is predicated on statutory requirements, supplemented by judicial decisions, the G.C. is a logical choice, especially because the CEO may be involved in more strategic initiatives and other matters that take precedence, as well as because the GC is in a better position to assess potential legal ramifications of compliance issues.
    If the CCO reports to the GC, the GC should bring to the Executive Committee’s prompt attention, any issues, challenges, or opportunities uncovered by the CCO (assuming the CCO did not also participate in the Executive Committee meetings.
    In smaller companies where routine communications are orally based, or there is no committee of the executive officers, the CCO could report to the GC, or might participate in a regularly scheduled meeting with the GC and CEO if warranted.
    Stephen Nagin
    CLO, Morgan Drexen, Inc.