CEO Annual Certification

What this video covers

• Why the CEO must personally sign the annual certification and cannot delegate this duty to the chief compliance officer (CCO) or in-house counsel
• The five specific processes the CEO certifies are in place: establish, maintain, review, test, and modify WSPs
• The required CEO-CCO meeting agenda and why it must occur within the preceding 12 months, not just calendar year
• Why a meeting between the CCO and any other officer (chief operating officer, legal, etc.) fails to satisfy the requirement
• How the rolling anniversary deadline works for the certification itself versus the 45-day clock for the board report
• Which report goes to which audience: supervisory control report to senior management, CEO certification supporting report to the board of directors
• Why exam fact patterns involving late board reports (even 50 days) state a clear violation while on-time certifications do not