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Minimizing the Risk of CCO Liability

Recent enforcement actions have made it clear that Chief Compliance Officers are at risk of personal liability if regulatory violations happen under their watch­. Building robust supervisory structures that clearly define roles and responsibilities can help limit potential CCO exposure. Join Scott Noah, Of Counsel at Stevens & Lee and Chief Compliance Officer of Griffin Financial Group, for practical guidance on how the right supervisory structure can reduce the risk of CCO liability, including:

  • Current standards for CCO liability
  • Compliance vs. supervision
  • The importance of the Empowered CCO
  • Developing policies, procedures and controls tailored to a firm’s business model
  • Managing the role of the CCO serving multiple functions
  • How technology provides the backbone of an effective supervisory structure


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Scott Noah has more than 35 years’ experience serving in senior legal and compliance roles in the financial services industry. He is currently Of Counsel at Stevens & Lee, a full-service law firm representing clients across the country. In this role, Mr. Noah  provides legal and compliance advice to a broad range of financial institutions, with an emphasis on the investment advisory and broker-dealer arenas. Mr. Noah also serves as Chief Compliance Officer of Griffin Financial Group, Stevens & Lee’s broker-dealer affiliate. 

Previously, Mr. Noah was General Counsel and Chief Regulatory Officer for Fieldpoint Private Holdings, Inc. and its affiliated entities, Fieldpoint Private Bank & Trust and Fieldpoint Private Securities, LLC., with responsibilities spanning all aspects of the organization’s legal, compliance and regulatory programs for the its wealth management and banking divisions. Mr. Noah chaired Fieldpoint Private’s  Management Compliance Committee, was an advisory member of the Board Governance & Nominating Committee, and served as senior advisor to the Board of Directors and the Board Audit Committee. He was also a member of the Board of Directors of Fieldpoint Private Securities, LLC.  Prior to joining Fieldpoint Private, Mr. Noah spent 12 years at UBS AG where, for the second half of his tenure, he served as General Counsel of the Wealth Management Americas International Division, which consisted of the US Private Bank and a dual-registered SEC investment advisor and full-service broker-dealer. Earlier in his career, Mr. Noah served in senior roles at institutions including UBS PaineWebber, Guardian Life Insurance, Gilder Gagnon & Howe, Smith Barney and the New York and American Stock Exchanges. 

He holds JD and MA degrees from Fordham University, and a BA from the City University of New York. Mr. Noah was a recipient of the 2018 Drinker Biddle First Chair Top General Counsel award.

Scott Noah
Of Counsel, Stevens & Lee