David Smyth

David Smyth

Brooks Pierce

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SEC Says No More Mr. Nice Guy on Investment Adviser Cybersecurity

Over the last couple years, the SEC’s cybersecurity bark has been worse than its bite. Its Office of Compliance, Inspections, and Examinations issued examination priorities in 2014. Commissioner Aguilar warned public...more

9/23/2015 - Broker-Dealer Brokers Cybersecurity Industry Examinations Investment Adviser OCIE Regulation S-P SEC Security and Privacy Controls

SEC Releases Results of Cybersecurity Exam Sweep

We’re a bit behind on this, but better (a little bit) late than never. Last month the SEC’s Office of Compliance, Inspections and Examinations released the first results of its Cybersecurity Examination Initiative, announced...more

3/17/2015 - Broker-Dealer Compliance Cybersecurity FFIEC FinCEN Industry Examinations Investment Adviser NIST OCIE SAR SEC

Caution: Aggressive Interpretation of Broker-Dealer Registration Provisions Could Be Hazardous to Your Ability to Stay out of...

Let’s do some compare and contrast, starting with a fairly unremarkable case the SEC filed in the Northern District of Texas on November 20th. In that action, the Commission sued the father-son duo of Paul and Jeffrey Downey...more

12/2/2014 - Broker-Dealer Mineral Leases Oil & Gas Registration SEC Securities Fraud

SEC Sanctions Auditor, Should Make Small Issuers Think Twice

The SEC brought a settled administrative action against an auditor on October 24th. Often I’ll take a case like this and write something about it to warn other auditors (or investment advisers or broker-dealers, or whomever)...more

11/4/2014 - Auditors Audits Broker-Dealer Compliance Enforcement Investment Adviser SEC

SEC Issues Risk Alert, Smacks E*Trade on Penny Stock Sales

On October 9th the SEC brought a settled administrative action against E*Trade Securities and G1 Execution Services (formerly E*Trade Capital Markets) for their part in the unregistered sales of billions of shares of penny...more

10/24/2014 - Broker-Dealer E*Trade Enforcement Actions Risk Alert SEC

Unregistered Brokers: Watch out for Shortcuts

One of the things I’ve learned since returning to private practice three years ago is that people like to raise money for profitable enterprises when they can. And why not? It can be lucrative. And if the people raising...more

8/21/2014 - Broker-Dealer Brokers Compliance SEC

The SEC Does Not Care about Your FINRA Document Request

If you are a broker-dealer or a registered representative at one, you sign on for some meddling by FINRA. The self-regulatory organization is responsible for overseeing your securities business and even for your outside...more

5/9/2013 - Broker-Dealer Document Requests FINRA SEC

SEC Highlights Compliance and Ethics for Broker-Dealers

On Tuesday the SEC held a National Compliance Outreach Program for Broker-Dealers at an open meeting at its D.C. headquarters. The first panel – titled The Role of Compliance and Ethics – was nominally targeted to...more

4/11/2013 - Broker-Dealer Chief Compliance Officers Compliance Corporate Culture FCPA Risk Management SEC

SEC Ramps Up Its Private Equity Parade

Bruce Karpati, chief of the SEC’s Asset Management Unit, promised us several weeks ago that enforcement actions against private equity firms were about to heat up. He wasn’t kidding. Last Monday, the SEC filed two sets of...more

3/21/2013 - Broker-Dealer General Solicitation Private Equity Ranieri Partners Registration SEC

SEC Charges Indian Firms with Acting as Unregistered Broker-Dealers

On November 27th, the SEC charged four Indian financial services firms with acting as unregistered broker-dealers in the United States....more

1/8/2013 - Broker-Dealer Enforcement Enforcement Actions India Registration SEC

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