The Society of Corporate Compliance and Ethics (SCCE) today announced it has filed comments with the U.S. Securities and Exchange Commission related to its Draft Strategic Plan for Fiscal Years 2010-2015. The SCCE filing addresses both the Commission’s role in regulatory and enforcement actions and the Commission’s position as a government agency developing and implementing its own compliance and ethics program.

"The SCCE applauds the Commission's recognition of the value of compliance and ethics programs as outlined in the Draft Strategic Plan," said Joseph Murphy, SCCE Director of Public Policy. "Our suggested additional steps are meant to support their efforts and help the Commission achieve its stated goals."

The SCCE sets forth its suggested additions to the Draft Strategic Plan in a nine-page filing written by Joseph E. Murphy, SCCE Director of Public Policy and SCCE Member Attorney Jeffrey Kaplan. The comments are also endorsed by SCCE Chief Executive Officer Roy Snell and SCCE Advisory Board Co-Chairmen Odell Guyton and Daniel Roach. (Link to SCCE filing here: http://www.corporatecompliance.org/SEC-draft-fy1015)

"We believe the SEC, through active support of compliance and ethics programs, has an unprecedented opportunity to enhance compliance with the nation's securities laws in a way that will more securely protect the interests of the investing public." Said Murphy

Comments
In its filing, the SCCE also suggests that the Commission’s Plan include the implementation of an effective, state-of-the-art compliance and ethics program for the agency itself.

"There is no better way for an organization to bring its professed values to life than by making the type of senior management commitment called for in such a program," Added Murphy. The filing quotes Chairman Schapiro as saying: "It only makes sense that we have a world-class compliance program "“ just as we expect from those we regulate." The SCCE notes that such a program should include a chief ethics and compliance officer who is fully empowered, independent, professional, and with a seat at the table for important Commission actions.

The SCCE commends the Commission for encouraging within organizations of all sizes a strong ‘culture of compliance.’ and proposes a number of additional steps in the Strategic Plan to make this happen, which include:

- extend compliance efforts to all segments regulated by the SEC, including publicly traded companies, not just registered participants in the securities industry;

- publicize information relating to the adequacy or inadequacy of compliance efforts resulting from Commission action both with respect to registrants and issuers;

- actively participate in the functions and programs of compliance and ethics professional organizations;

- designate within the Commission a subject matter office to focus commission efforts to promote more effective compliance and ethics programs for all participants in the securities markets subject to the Commission’s jurisdiction;

- include "compliance and ethics programs" in the areas of focus for the Commission’s initiative to improve the quality and usefulness of registrants’ disclosures to investors;

- apply state-of-the-art approaches to the Commission’s own compliance and ethics program;

- conduct a rigorous risk assessment to determine what compliance, ethics, and reputational risks confront the Commission as an initial step in developing its compliance program; and

- seek interaction with compliance and ethics professionals through round tables, public hearings, seminars and soliciting public comment on draft policy documents as part of the agency’s effort to assess its performance in the compliance and ethics field.

Murphy observes: "As the Commission itself wisely points out in the draft plan, "working to prevent future violations can be even more important" than detecting violations after the harm has occurred. If the Commission talks directly to the ethics and compliance community and makes it clear that real programs"“ not mere paper programs, but serious management commitments "“ do count, it can do much more to protect the public than any other regulatory or enforcement initiative."

To review the complete SCCE filing with the SEC, click here: http://www.corporatecompliance.org/SEC-draft-fy1015

About the SCCE
The Society of Corporate Compliance & Ethics (SCCE) is headquartered in Minneapolis, MN. Its mission: SCCE exists to champion ethical practice and compliance standards in all organizations and to provide the necessary resources for compliance professionals and others who share these principles.

Visit the SCCE Web site at www.corporatecompliance.org, Toll-Free Tel: 888-277-4977. Society of Corporate Compliance & Ethics is located at 6500 Barrie Road, Suite 250, Minneapolis, Minnesota 55435. E-mail: helpteam@corporatecompliance.org

Society of Corporate Compliance and Ethics

Society of Corporate Compliance and Ethics

The Society of Corporate Compliance & Ethics (SCCE), headquartered in Minneapolis, MN, is a non-profit organization dedicated to enhancing the role of compliance professional, and advancing corporate governance, compliance and ethics on a global scale. Its mission is to champion compliance standards, corporate governance and ethical practice in the business community, and to provide the necessary resources for compliance and ethics professionals and others who share these principles. Society of Corporate Compliance & Ethics is located at 6500 Barrie Road, Suite 250, Minneapolis, Minnesota 55435.

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