In a little over 11 weeks, firms are going to have to hire a chief compliance officer, a requirement that could prove to be a tall task for fund shops, particularly smaller ones.

The key date is Oct. 5. That is when the Securities and Exchange Commission has said firms must have a CCO, a single person "competent and knowledgeable" in federal securities laws, with responsibility for the overall management of a fund complex's compliance program. The CCO will report directly to the board of directors, which is the only group that can hire, or fire, the compliance chief.

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