In this issue;
- SEC to Hold Roundtable to Discuss Conflict Mineral Rulemaking
- SEC Staff Issues Risk Alert on Master/Sub-account Risks
- Fraudulent Statements That Maintain Inflated Price Can Support Securities Fraud Claims
- Provision of Credit Card Receipt Is Not A “Publication” That Triggers Duty To Defend
An excerpt from "SEC Staff Issues Risk Alert on Master/Sub-account Risks"
A master/sub-account arrangement exists where the same beneficial owner maintains multiple sub-accounts; the beneficial ownership interests in the various sub-accounts may or may not be identified to a broker-dealer. On September 29, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations released a National Exam Risk Alert (the Alert) on risks associated with master/sub-account arrangements. In the Alert, the SEC’s National Exam Program (NEP) identified a number of potential risks associated with master/sub-account arrangements. Specifically, NEP identified the following potential risks..
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