New CCO Reg. Category

Quick note on proposed Rule 1230(a)(4). Reference: Notice 09-70.

The rule makes a stand-alone registration category for Chief Compliance Officers, which will require a new qualification examination. Here are some reminders:

• If you are already on Form BD as CCO when the rule is made effective, you'll be 'grandfathered' and won't have to take the new test. You will be registered as CCO via a U4 amendment.
• This includes any person listed on Form BD, such as co-CCO's and limited principals filling that role.
• If you are added to Form BD after the effective date of the rule, but before the new examination is available, you will likewise be grandfathered, BUT only if you hold a 24. That is, if you are a limited principal and the firm adds you as CCO in this interim period, you will not qualify for the freebie CCO registration--you'll have to take the 24 or wait and take the new CCO exam.
• If you are added to Form BD after the effective date of the rule and after the new examination is available, you will have to pass the exam first before your CCO registration is approved. Even if you have a 24...it won't matter.

So think about this and plan accordingly. I'm not sure when the rule will be approved. See this link for links to Comments about the proposal.