A subject of significant debate within many corporations and between corporate America and enforcement agencies is the place and status of corporate compliance professionals within the corporate organizational chart. Government would like to see the compliance function in a top tier of an entity's hierarchy, perhaps at the vice president level, with direct access to the board and CEO. In addition, government recommends against compliance professionals reporting to either the General Counsel or the Chief Financial Officer. By contrast, many corporations prefer having compliance at a director level position, reporting to the General Counsel, with periodic appearances before the Board's Audit/Compliance Committee. This is also the position taken by the American Bar Association. Do Caremark, the OIG Compliance Guidelines, or the Federal Sentencing Guidelines provide any guidance to you on this issue? Based upon your understanding of the law and its rationale, what recommendations would you make regarding the place of compliance professionals within the organizational structure?