Size Matters…and Other Compliance Myths

Parker Poe Adams & Bernstein LLP
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The recently released Society of Corporate Compliance and Ethics 2017 Compliance and Ethics Officer and Staff Salary Survey contains a host of interesting CCO and other compliance personnel compensation information. Also interesting is the survey’s profile data regarding compliance professionals and their companies.

The SCCE is a nonprofit association of more than 5,800 members, including CCOs and their staffs, employed in a wide range of industries. The 2017 survey’s data was derived from 1,376 email responses, which were then distilled down to 444 individuals employed by non-health care providers and responsible for at least 26 percent of their organization’s legal and regulatory risk (i.e., actual compliance personnel rather than personnel with isolated compliance duties).

A review of the survey’s data exposed five common compliance myths.

Myth No. 1: Only public companies have compliance departments.

In fact, the survey indicates that only 24 percent of responding CCOs work at publicly traded companies, while fully 39 percent were employed by private companies. The remaining CCOs work for governmental agencies, academic institutions and nonprofits.

Myth No 2: Only mega-companies have compliance departments.

The reality is that 41 percent of responding CCOs work at organizations with fewer than 1,000 employees. The numbers rise to 57 percent for companies under 3,000 employees and 72 percent for those under 7,500 employees.

Similarly, 52 percent of responding CCOs work at organizations with annual revenues of less than $500 million, 35 percent at organizations with less than $100 million and 27 percent at those with less than $50 million.

Myth No. 3: Most compliance professionals are involved in only a small slice of the company’s legal and regulatory risk.

The SCCE survey indicates that 42 percent of respondents are involved in more than 75 percent of the company’s risk, while 73 percent were involved in more than half.

Myth No. 4: CCOs have only shoestring budgets to work with.

This one is a little harder to refute because every CCO I’ve ever spoken to genuinely bemoans his or her limited budget and the resulting impediments to necessary initiatives. Nevertheless, the survey shows that the typical CCO manages an annual budget of approximately $500,000. More than a third manage a budget of more than $1 million, with 16 percent at more than $2 million.

Myth No. 5: CCOs are poorly compensated.

CCO annual compensation has been on the rise as the profession has gained prominence and credibility. As with most jobs, experience makes a difference, with average annual total compensation ranging from $123,000 (for less than three years of experience in the compliance profession) to $232,000 (for 21 or more years of experience). As you might expect, average total compensation was highest at publicly traded companies ($237,000) and lowest at governmental agencies ($140,000). Those working in the pharma/medical device industry had the highest average total compensation ($275,000), followed by consulting services ($239,000), information technology ($225,000) and financial services ($219,000).

My main takeaway from the SCCE’s survey is that, as compliance programs go mainstream, the compliance profession is gaining stature and responsibility across all industries and all sizes of companies.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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