Operational Professional Registration

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 […]

Whistleblowing–Are you prepared?

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 […]

How Do You Create a Real Culture of Compliance?

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, […]