I have the privilege of being elected to serve as NRA’s first Chief Compliance Officer (CCO). I would like to thank the members for voting overwhelmingly to amend the bylaws to create the CCO position. I would also like to thank the Board of Directors for their support and confidence in elevating me to the position.
There is no more important goal in my compliance role at the NRA than to restore the members’ trust and confidence by demonstrating that the NRA has learned from its past and is committed to compliance and integrity.
Let me share two quick and plain observations when I came aboard almost a year ago:
No. 1: The NRA is only as strong as its members. Without loyal members, there is no NRA.
No. 2: The NRA employees and Board members are committed to compliance and integrity and moving forward. No one suffered as much from our past indiscretions as our dedicated, patriotic employees who come to work every day to do the right thing.
Naturally, because this is a new position, the NRA receives questions regarding the scope of this new role, reporting structure, hiring process and my background. I hope to help answer these questions below.
CCO Responsibilities
The Bylaw amendment provides additional details of the CCO’s responsibilities, but, in short, the CCO position is responsible for developing and implementing a well-designed compliance program that ensures the NRA adheres to its bylaws, policies, procedures and applicable laws. This is accomplished, in part, by implementing effective internal controls, policies, procedures and training. Additionally, the CCO and leadership are responsible for promoting a culture of compliance, integrity and ethics, where employees and others feel comfortable reporting noncompliance and misconduct matters.
Independence and Autonomy
It’s always critical for the CCO position to have the independence and autonomy needed to accomplish its mission, but most importantly to have the authority to do the right thing for the organization. Fortunately, the NRA Board recognized this and designed the CCO position to report directly to the Board through the Audit Committee and not through management like the majority of other corporations.
The reporting structure provides the position with the autonomy, independence and security needed to carry out the mission effectively and provides the Board’s Audit Committee with the appropriate level of visibility and oversight. At the same time, it is also important for the CCO to be transparent and keep leadership informed of any issues.
My Background
I served 25 years in federal law enforcement as a criminal investigator and manager for investigative agencies. During my law-enforcement tenure, I became a licensed attorney after attending law school at night. My post-government service includes working for two large global companies in various compliance, regulatory and legal roles, where I directed, built and strengthened compliance, integrity and regulatory programs in the United States and abroad. I also responded to government regulatory and investigative matters.
I was originally hired by the NRA as a Managing Director of Compliance so I could hit the ground running while waiting to see if the membership approved the bylaw amendment. The NRA Board’s Audit Committee was resolute that, even before the bylaw change, my position should report directly to the Audit Committee and be independent of NRA’s staff management reporting. Again, the purpose of this reporting structure is to be more transparent with the Audit Committee and the Board so they can effectively execute their oversight role.
As a result, the Audit Committee engaged an external executive search firm specializing in compliance to forward qualified candidates for review. NRA staff leadership was not involved in the selection process, which resulted in my selection. Having no affiliation with the NRA or its contractors was necessary so the position could objectively assess the state of compliance and bring outside experience to the program.
Where We ARE Now as an Organization
Prior to my arrival, the staff, especially the Financial Services and Legal departments, embarked on a plan to strengthen compliance. Internal controls, redundancy measures and training to improve our compliance framework. I also hired an experienced Director of Internal Audit and Compliance to test, monitor and improve the controls that are in place to prevent any one person from circumventing the controls.
Compliance is not static. It is always about continuous improvement, so there are no perfect compliance programs or organizations. Misconduct and noncompliance will occur within every organization. That is an unfortunate but obvious fact. However, how the organization reports, responds to and remediates those activities is what makes an effective compliance and ethics program. My government and corporate experience ensure that issues will be addressed appropriately.
With the support from the NRA’s Board, officers, management and staff, I am committed to honoring the trust and confidence of our members by continuously improving our compliance program and promoting integrity, accountability and transparency throughout the organization.
