This headline flashed across my computer screen a few days ago in an e-mail. SEC orders FINRA to improve compliance policies and procedures The SEC order arises from a whistleblower complaint. Prior to submitting records to the SEC, the regional director of the FINRA Kansas City office had minutes of the district office staff […]
Perhaps I spent too much time this weekend sitting in my apartment listening to the news and weather reports about the approaching hurricane, but on Sunday after the warnings were lifted and family and friends were safe, with the exception of a few power outages, I started to think about the similarity between the preparation […]
I am not aware of many broker-dealers that do not have, some, if not all of the operational professionals at senior levels registered. But clearly my experience did not spread across the entire industry. In case you missed the release (Reg. Not. 11-33) while you were away on vacation, effective October 17, 2011 certain operational […]
Branding Your Compliance Project. This is not original commentary but you might find it helpful as the end of year budget season approaches.
Tucked away in the Dodd-Frank Act is a new whistleblower provision. Under this provision an individual or group of individuals may collect awards of 10% to 30% of judgments or settlements with the SEC over $1 million. Not an insignificant amount of money. What do they have to do to get this reward? The whistleblower […]
If you have ever been a Chief Compliance Officer of a broker-dealer or investment adviser the question “what is your culture of compliance” will resonate. Each regulatory examination notification sends you off to various business persons with the news that they may be interviewed by the regulator and if they are very senior—CEO, CFO, CIO, […]
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