Kelley A. Howes

Kelley A. Howes

Morrison & Foerster LLP

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SEC Sanctions Three More Investment Advisers for Compliance Violations

The SEC’s Compliance Program Initiative bore more enforcement fruit. SEC today sanctioned three investment advisory firms for repeatedly ignoring compliance problems. The Initiative targets firms that fail to address...more

10/24/2013 - Compliance Investment Adviser Sanctions SEC

SEC Sanctions Investment Adviser for Pushing Class A Shares When Investors Qualified to Buy Institutional Class Shares

The Securities and Exchange Commission sanctioned an investment adviser and its owner for failing to seek best execution and breaching their fiduciary duty in selecting mutual fund share classes for three advisory...more

10/3/2013 - Broker Commissions Broker-Dealer Fiduciary Duty Investment Adviser Investment Advisers Act of 1940 Mutual Funds Sanctions SEC

Giving the CCO Teeth: SEC Sanctions Portfolio Manager for Misleading CCO

The SEC brought its first action for misleading and obstructing the work of a CCO this week, finding that a portfolio manager deliberately altered documents and misled the firm’s CCO in an attempt to hide violations of the...more

8/29/2013 - Chief Compliance Officers Compliance Ethics Investment Company Act of 1940 Misrepresentation Portfolio Managers Sanctions SEC

Broker-Dealer Email Systems Must Keep Pace with Firm Growth, FINRA Says

A recent FINRA disciplinary action sends a strong message to broker-dealers that the development of their compliance systems — particularly with respect to email review and retention — must keep pace with the growth of their...more

5/29/2013 - Broker-Dealer Discovery Email FINRA Recordkeeping Requirements Sanctions Supervision

SEC Sanctions Fund Trustees for Inadequate Disclosures and Failure to Follow Compliance Policies

The Securities and Exchange Commission today charged the trustees of two “turnkey” mutual fund trusts with causing untrue or misleading disclosures about their review of the funds’ advisory contracts. The Commission also...more

5/3/2013 - Chief Compliance Officers Compliance Duty to Disclose Sanctions SEC Trustees

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