General Counsel Interview with Sarah Schott

Sarah Schott is the General Counsel and Chief Compliance Officer of Gravie, a health benefits company that creates employer-sponsored health benefit solutions. She sets the overall legal and compliance strategy and helps mitigate legal and regulatory risk. She previously served as Chief Compliance Officer of Northwestern Mutual, where she was responsible for all regulatory compliance operations and chaired the Enterprise Compliance Committee. She has also served as Senior Managing Director, General Counsel and Corporate Secretary of B.C. Ziegler & Company, a publicly traded broker-dealer, mutual fund advisor and investment banking firm.

Why did Gravie decide to combine the roles of GC/CCO and hire at this time?

Schott: Gravie has experienced tremendous growth in recent years, and we expect the growth will continue to accelerate. Combining the GC and CCO roles makes sense at this point, given the need to integrate both legal and compliance perspectives into executive level conversations. Because we are in a highly regulated industry, it is critical that we have excellent oversight of operational and regulatory risks and develop repeatable, high-quality processes as the business adds scale quickly. That work draws heavily from the compliance side of the business. My prior experience as a GC of a financial services company and CCO of an insurance company helps me to wear both hats at the same time and know which role needs emphasis at any particular time. It is also valuable for compliance to have a strong presence in conversations at the board level during a time of rapid growth.

How big will your department be?

Schott: The GC position is new for Gravie, and we don’t yet have plans for adding more in-house positions. Gravie has an established team in the compliance space, including a vice president of operations and compliance with deep technical expertise and many years of experience in health insurance.

What legal specialties will particular members of your team have?

Schott: As a health benefits company, many of our legal issues involve the Employee Retirement Income Security Act (ERISA), health insurance and captive insurance company regulations, and privacy. Like other companies, we also have employment, general corporate and financing/fundraising-related legal work.

What do you look for in an attorney?

Schott: One of Gravie’s core values is “Why? Think. Ask. Explain.” Our lawyers — internally and externally — need to be role models in this space. I expect legal and compliance experts will take the time to listen and understand the goals of their business partners, affirm that they are working towards achieving business partners’ goals, explain options and risks, and communicate the “why” behind their recommendations. We obviously can’t always get to the outcome our business partners want or prefer, but it goes a long way to a partner’s trust in our advice when they know that we understand and support their goals.

What are the major litigation issues you anticipate?

Schott: Gravie has an exceptional track record with respect to litigation over the eight years it has been in business. Gravies’ strong commitment to putting the consumer first and developing innovative, high-value health insurance solutions has helped avoid any material litigation with respect to our claims and business processes. We have also built strong relationships with our employer customers, which minimizes litigation risk and leads to excellent retention rates. We know there may be bumps in the road, but our work to grow the company the right way and deliver a quality experience will help minimize our litigation risks overall.

Any thoughts on legal technology, the tech you’ve adopted and what, if any, you’ve rejected?

Schott: Since our in-house legal function is new, we get to build things from the ground up. We are currently exploring contract management solutions that are supportive of an efficient sales and servicing process, and management of many other contracts across the company. We’ve also recently added a platform to manage some corporate governance functions.