Whoops I mean you cant report to CIO - my bad.
I believe its a no. The CIO would then be in a position to influence compliance related matters and overpower the compliance officer (the potential)
This is similar to the question on the BSAS exam. Check it out.
http://www.cfapubs.org/doi/pdf/10.2469/ccb.v2004.n4.4008 “Where possible, the compliance officer should be independent from the investment and operations personnel and should report directly to the CEO or board of directors.” This is not absolute. “where possible”
and “Depending on the size and complexity of the Manager’s operations, some Managers may designate an existing employee to also serve as the compliance officer”
true, but you wouldn’t designate an employee that reports to CIO and CEO in my view.
The question had to do with reporting. So okay - can not be independant from investment and operations personnel, but in terms of reporting - must be to CEO or BOD.
compliance officer cannot report to CIO, clearly stated in the AMC. regarding the material non public info, i answered that it was diligence and reasonable basis, since they came to thier own conclusion
He was reporting to the CEO.