David Smyth

David Smyth

Brooks Pierce

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SEC CustodyFest Vol. 1: A New Beginning

Imagine being Andrew Bowden. As director of the SEC’s Office of Compliance, Inspections and Examinations, you know you don’t have enough staff to conduct reasonably regular exams of registered investment advisers. You also...more

11/12/2013 - Books & Records Custody Rule Customer Funds Protection Fraud Investment Adviser SEC

SEC Staff Seeking Hard Drives, Etc. (but without authority)

Last month brought us this story from Reuters, in which we learned that the SEC “has become more aggressive in seeking full hard drives from the companies and individuals it investigates, startling defense lawyers who...more

2/12/2013 - Books & Records Investigations Release of Information SEC Securities Exchange Act

SEC Charges Allianz with FCPA Violations

On December 17th, the SEC brought a settled administrative FCPA action against Allianz SE, a German insurance company with a subsidiary in Indonesia. The order does not allege violations of the FCPA’s antibribery provisions,...more

1/2/2013 - Allianz Books & Records FCPA SEC Subsidiaries Voluntary Disclosure Whistleblowers

SEC’s Asset Management Unit Focuses on Compliance Failures, Vol. 2

As we discussed last month, the SEC’s Asset Management Unit has developed a likeness for not just big, headline-grabbing cases, but relatively small compliance-based cases that are designed to prevent minor problems from...more

12/19/2012 - Asset Management Unit Books & Records Compliance Investment Adviser Registration SEC

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