If the Chief Compliance Officer (CCO) works at a location where there are no registered representatives, is the location required to be registered as a branch?
It depends on the function/activities occurring at the location. In some firms, Compliance serves a control function, similar to Internal Audit, and is not part of the supervisory structure. If this is the case, then the location from which the CCO works would not have to be a registered branch, presuming there are no other activities at the location that would require the location to be registered as a branch. In some firms, however, Compliance may serve a supervisory role. If the CCO is supervising the activities of associated persons at other non-branch locations, then the CCO’s location would have to be registered as a branch office. Further, if the CCO is supervising the activities of associated persons at other branch locations, then the CCO’s location would be designated an OSJ.
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