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Determining Chief Compliance Officer Liability Isn’t Really That Confounding

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

Equitable’s Settlement With The SEC Demonstrates That A Single Customer Complaint Can Serve As Notice Of A Systemic Issue

Last week I posted a blog about the dangers of not heeding findings made during a regulatory exam, at least findings of clear, undisputable compliance issues that cannot be meaningfully defended. Today I am writing to...more

The Very Pricey Real Estate At The Intersection Of The Old Books-And-Records Rule And The New Reality Of How People Communicate

Happy New Year! I hope you had an enjoyable holiday season. At least happier than that of JP Morgan Securities, which, right before Christmas, got to write checks to the SEC and the CFTC totaling $200 million. That’s a...more

SEC Settlement Is A Wake-Up Call To Review Outdated Procedures

Most securities regulations, by design, create a gray world where compliance is not crystal-clear, but, rather, subject to interpretation. After all, what you think constitutes “reasonable” supervision and what FINRA or the...more

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

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

Another Fine Churning Mess

While undoubtedly FINRA will be issuing its annual “examination priorities” letter any day now, that is hardly the best way to figure out exactly what FINRA is paying attention to now (as that letter kind of reads the same,...more

The SEC’s New Marketing Rule: Bringing Investment Adviser Advertising From The “Mad Men” Era To The Amazon Age

“The SEC score(s) one for the digital age.” These are the words of SEC Commissioner Heist, though, not my own. After a nearly year-long comment period, the SEC announced last week that it was replacing its former advertising...more

FINRA Rule 8210

I hope that you have had the chance to enjoy Jessica Hopper’s paean to Rule 8210 in her recent blog posted on FINRA’s website. Very disturbing, and for all the old reasons. First, once again, she starts by patting herself –...more

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