News & Analysis as of

Chief Compliance Officers Broker-Dealer

Lowenstein Sandler LLP

Another Wave of SEC Settlements Underscore the Continued Priority of Record Retention Communication Compliance

On August 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements regarding “off-channel communications.”1 As part of its Off-Channel Communications Initiative,2 the SEC settled...more

Katten Muchin Rosenman LLP

Six Takeaways From FINRA's Revised Sanction Guidelines

The Financial Industry Regulatory Authority (FINRA) Sanction Guidelines have been significantly revised, now giving FINRA discretion to impose considerably higher fines on mid- and large-size firms. The revisions, published...more

UB Greensfelder LLP

Determining Chief Compliance Officer Liability Isn’t Really That Confounding

UB Greensfelder LLP on

About a month ago, the SEC announced a settlement in a modest little case that has, nevertheless, managed to garner a lot of attention.  This is a result of the fact that one of the respondents was the CCO, i.e., the Chief...more

Dechert LLP

Supervisory Liability for CCOs Under FINRA Rule 3110

Dechert LLP on

The Financial Industry Regulatory Authority issued a regulatory notice clarifying the scope of supervisory liability under FINRA Rule 3110 of a broker-dealer’s chief compliance officer (CCO) (Regulatory Notice). FINRA’s Head...more

Latham & Watkins LLP

When Are CCOs on the Hook? FINRA Offers Guidance on CCO Liability

Latham & Watkins LLP on

Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors for and against charging compliance officials. On March 17, 2022, the...more

UB Greensfelder LLP

Highlights From SIFMA’s Compliance And Legal Seminar 2022

UB Greensfelder LLP on

I attended the four-day SIFMA Compliance and Legal seminar last week, and there were a bunch of interesting soundbites from regulators that folks might find interesting. The challenge at these conferences is always...more

Faegre Drinker Biddle & Reath LLP

FINRA Wades into the Controversial Deep-End of CCO Supervisory Liability

The lack of specific guidance regarding failure to supervise liability for chief compliance officers (“CCOs”) has been a controversial and opaque topic that both FINRA and the SEC have struggled with for well over a decade....more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #54

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: An Overview - This article is an overview of the requirements of PTE 2020-02. It discusses the expanded fiduciary definition, the conditions in the PTE, and the...more

Faegre Drinker Biddle & Reath LLP

NYC Bar Association Proposes a CCO Enforcement Framework

Responding to a “concern” from Chief Compliance Officers (CCOs) to the purported increase in enforcement actions holding compliance personnel personally liable, the New York City Bar Association recently released a framework...more

Lowenstein Sandler LLP

2020 and Q1 2021 Developments And Annual Compliance Checklists

Summaries of recent legislative and regulatory developments with respect to: •The SEC’s Examination Priorities for 2021- •The SEC’s Focus on Digital Asset Securities- •The SEC’s New Marketing Rule... ...more

UB Greensfelder LLP

SEC Settlement Proves That When CCOs Spot A Problem, Silence Is Not Golden

UB Greensfelder LLP on

A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more

UB Greensfelder LLP

[Webinar] FINRA 2021: What to Expect - February 24th, 2:00 pm - 3:00 pm EST

UB Greensfelder LLP on

Join Ulmer partners Alan M. Wolper and Michael A. Gross as they address hot topics, including recent rule changes, exam priorities, and other FINRA developments....more

UB Greensfelder LLP

[Webinar] Data Protection & Cybersecurity Challenges for Financial Institutions in 2021 - February 17th, 2:00 pm - 3:00 pm EST

UB Greensfelder LLP on

Join Frances Floriano Goins and Laura J. Shaw, Associate General Counsel from KeyBank, NA, as they review the myriad regulatory schemes that govern data protection for financial services providers, keying in on both newly...more

UB Greensfelder LLP

[Webinar] SEC Update: Reg BI, Enforcement Activity, and the Willfulness Standard - February 11th, 2:00 pm - 3:00 pm EST

UB Greensfelder LLP on

Join Heidi E. VonderHeide as she discusses how Regulation Best Interest is being implemented, examines post-effective date guidance and activity by the regulators, and shares what to expect during 2021 exams. Heidi will also...more

UB Greensfelder LLP

[Webinar] FINRA Expungement: Rule Changes and Updates - February 9th, 2:00 pm - 2:30 pm EST

UB Greensfelder LLP on

Join Christopher D. Seps as he discusses the rule changes that recently took effect related to FINRA’s expungement process, as well as proposed changes that will likely be approved and take effect in 2021. These changes...more

UB Greensfelder LLP

Let’s Hear It For CCOs; After All, They Are Human People

UB Greensfelder LLP on

We have frequently blogged here about the degree of attention that regulators pay to Chief Compliance Officers, and whether it is proper that they sometimes are named individually in Enforcement actions. And we are hardly...more

Proskauer - The Capital Commitment

Private Equity and Cybersecurity: A Guide to Preparing for and Responding to a Breach

A cyber breach can have serious legal, financial, and reputational consequences for a fund sponsor, as described in our previous post. As such, cybersecurity threats must be treated as business risks, not just a potential IT...more

NAVEX

3 Coronavirus Compliance Tips From the SEC

NAVEX on

The coronavirus crisis is far from over, and compliance professionals still need every scrap of guidance that regulators can provide about how to run compliance programs in these difficult times. So when the Securities and...more

A&O Shearman

COVID-19: Compliance and Legal Considerations for Asset Managers

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As the world responds to COVID-19, we have identified a number of compliance and legal considerations for asset managers. We summarize a select list of these in our note below....more

Katten Muchin Rosenman LLP

Bridging the Weeks - October 2019

Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more

McGuireWoods LLP

SEC Opens Cease-and-Desist Order Proceeding against Broker-Dealer and Chief Compliance / AML Officer

McGuireWoods LLP on

As we have highlighted in prior posts, regulators of financial institutions, including FinCEN, FINRA and SEC, have increasingly brought actions to bring organizations – and individuals – into compliance with AML / BSA...more

BCLP

SEC Brings AML Charges Against New York Brokerage Firm and its Chief Compliance Officer

BCLP on

The SEC recently charged a New York-based broker-dealer, Windsor Street Capital, L.P. (f/k/a Meyers Associates, L.P.) and John David Telfer, who acted as Windsor’s Chief Compliance and Anti-Money Laundering Officer for...more

Blank Rome LLP

Regulatory Update and Recent SEC Enforcement Actions

Blank Rome LLP on

FINRA Bar Results from Assertion of Fifth Amendment Right against Self-Incrimination in Criminal Action - On October 5, 2016, the Financial Industry Regulatory Authority (“FINRA”) barred an indicted investment adviser,...more

Morgan Lewis

Broker-Lite: FINRA Built It, But Will They Come?

Morgan Lewis on

On August 18, 2016, the US Securities and Exchange Commission (SEC) approved a new Financial Industry Regulatory Authority (FINRA) rule series intended as a “lite” framework for the registration and regulation of brokers that...more

A&O Shearman

Securities Enforcement: 2016 Mid-Year Review

A&O Shearman on

The Securities and Exchange Commission (the SEC or the Commission) brought over 400 enforcement actions in the first half of 2016 and is on pace to surpass its record of 807 enforcements actions in a single fiscal year, which...more

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