A General Counsel Roundtable survey in 2007 collected from one hundred law departments the “non-legal” functions that fall to the general counsel. Compliance ranked third after Corporate Secretary and Corporate Governance (See my post of Jan. 18, 2008: “Corporate Governance”.). Fine, but the percentage of respondents who said that Compliance is within the set of responsibilities of the chief legal officer was a surprisingly high 70.6 percent.
Posts on this blog have described other surveys’ results on the frequency of compliance reporting to the legal functions, and they haven’t come up with such a high percentage (See my post of Nov. 1, 2005: one-third to general counsel; June 11, 2008: 20% of “top compliance executive” report to the general counsel; and Oct. 21, 2005: where should compliance report if not to law.).
Other posts comment on compliance-law reporting (See my post of May 20, 2005: compliance and law together; July 31, 2005: compliance and law within same group; and Dec. 22, 2005: law department relationship to ethics and compliance heads.).
Still a third set of posts look at reporting lines of the compliance function in specific industries (See my post of Jan. 16, 2006: health care companies; and Feb. 7, 2006: financial institutions.) while others cite specific companies (See my post of Sept. 17, 2005 #2: at Citigroup, compliance reports to chief risk officer; Nov. 16, 2005 #1: at Raytheon, Chief Ethics Officer and Chief Compliance Officer report to GC; and Jan. 17, 2006 #1: at McDonald’s, compliance reports to GC.).