News & Analysis as of

Professional Disciplinary Actions Securities and Exchange Commission (SEC)

King & Spalding

Recent Enforcement Trends Regarding the Use of Off-Channel Communications on Personal Devices

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What U.K. Firms Need to Know - INTRODUCTION - Over the past decade, the use of messaging applications, such as WhatsApp, for business purposes as an alternative to traditional email has grown exponentially. Ease of use...more

UB Greensfelder LLP

Time Never Matters To Regulators, Until It Does

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As the song goes, time keeps on slipping, slipping, slipping into the future. While Steve Miller may not have had FINRA and the SEC in mind when he wrote that lyric, the shoe certainly fits. Because here’s the thing about...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

UB Greensfelder LLP

A Sad Story Of Regulators Simultaneously Doing Too Much And Too Little

UB Greensfelder LLP on

Not too long ago, a single, small BD experienced a bizarre combination of regulatory overzealousness and regulatory indifference, by the SEC and FINRA, respectively. These things, sadly, happen all the time, but what...more

UB Greensfelder LLP

If You Supervise Yourself - Which You Cannot Do - Make Sure You Do It Right

UB Greensfelder LLP on

I have always operated with the understanding that, per FINRA rules, one cannot supervise him- or herself. Hardly an outrageous proposition. Today, however, that fundamental, bedrock understanding was so shaken, it has left...more

UB Greensfelder LLP

SEC Not Only Reverses FINRA Disciplinary Action, But Provides Blueprint For Respondents To Use In Their Defense Of Similar Claims

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My friend and former colleague, Brian Rubin, publishes annually his analysis of FINRA Enforcement cases, spotting trends in terms of the number and types of matters it brings, the sanctions meted out, etc. It is an excellent...more

UB Greensfelder LLP

The (Possible) Benefit Of Self-Reporting And Internal Discipline

UB Greensfelder LLP on

Historically, one of the surest ways to get yourself permanently barred from the industry is to forge a customer’s signature on something. According to the pertinent Sanction Guideline, at a minimum, a forgery, that is, a...more

UB Greensfelder LLP

FINRA AWC Provides New Defense To Allegation Of “Willfulness”

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I dare you. In fact, I double-dog dare you to figure out how or why FINRA decides to charge willfulness in some cases but not in others. Bottom line is that it is nearly impossible (except if you’re a big firm, in which case...more

Katten Muchin Rosenman LLP

Bridging the Week - November 2019 #2

A social media company and its wholly owned subsidiary sued by the Securities and Exchange Commission for conducting an offering of an unregistered digital security claimed that the agency was wrong in its characterization of...more

Katten Muchin Rosenman LLP

Bridging The Week - September 2019 #4

Both the Commodity Futures Trading Commission and the Chicago Board of Trade settled related disciplinary actions for speculative position limits violations. The CFTC sanctioned the trading firm while the CBOT sanctioned the...more

Kramer Levin Naftalis & Frankel LLP

OCIE Releases Risk Alert on Compliance Issues Related to Investment Advisers’ Supervised Persons With Disciplinary History

On July 23, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert setting forth compliance issues that OCIE had observed during its series of examinations of SEC-registered investment...more

Katten Muchin Rosenman LLP

Bridging the Week - February 2019 #3

The US Department of Justice vehemently opposed the request for a new trial by the first person charged, convicted and sentenced under the Dodd-Frank Wall Street Reform and Consumer Protection Act’s prohibition against...more

Sheppard Mullin Richter & Hampton LLP

Recent Development in Regulatory Enforcement of Digital Securities

In a flurry of activity and confluence of developments, the SEC, FINRA and a Brooklyn federal judge have commenced actions and made rulings that continue to define the regulatory framework and obligations surrounding the sale...more

Bass, Berry & Sims PLC

Chris Lazarini Analyzes Case Alleging Conspiracy Against FINRA and an Email Archiving Vendor

Bass, Berry & Sims PLC on

Bass, Berry & Sims attorney Chris Lazarini analyzed a case in which Plaintiffs, attempting to overcome an earlier dismissal of their claims, alleged a conspiracy between an email archiving vendor and FINRA in support of their...more

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