In many instances, the Dodd-Frank Wall Street Reform and Consumer Protection Act merely set a framework for financial reform and left much of the heavy lifting to the financial regulatory agencies. The SEC published their agenda for the implementation of Dodd-Frank. It is a long list. Compliance leaders are going to very busy keeping track [...]
Tag Archives: SEC
Why Is It Called a “Wells Notice”?
In 1972, SEC Chairman William J. Casey appointed a committee to review and evaluate the Commission’s enforcement policies and practices. Chairman Casey appointed John A. Wells, a lawyer at Royall, Koegel & Wells in New York, to the committee. He also added and former SEC Chairmen Manny Cohen and Ralph Demmler. Chairman Casey asked Jack [...]
Private Equity and the Custody Rule
With the impending removal of the 15 Client Rule exemption from registration with the SEC, I was scratching my head trying to figure how to make the SEC’s new custody rule work for private equity. The SEC recently updated its guidance on custody rule compliance truing to add clarity for advisers to pooled investment vehicles. [...]
Feds Release Usable Model Consumer Privacy Notice
There was much cheering when federal regulators finally released their Final Model Privacy Notice Form back in November. That was quickly followed by a gnashing of teeth when it turns out the regulators did not understand the concept of a form or how to use Adobe Acrobat. They merely created a static document that you [...]
FINRA and Placement Agents
Will FINRA step in to prevent a ban on placement agents working with government investors? You may remember that last August, the SEC published a proposed rule that would create a prohibition on paying a third party, such as a placement agent, to solicit a government client on behalf of the investment adviser: IA-2910. The [...]
Did you “Make” an Untrue Statement under 10b-5?
The First Circuit threw out the SEC’s 10b-5(b) claim in SEC v. Tambone. This time it was the entire court after an earlier decision of a three judge panel reached the opposite decision. The SEC alleged that James Tambone and Robert Hussey engaged in fraud in connection with the sale of mutual fund shares tied to [...]
New Anti-Money Laundering Guidance
Money Laundering is bad and financial institutions need to have internal controls policies, procedures and processes to identify higher-risk accounts and monitor the activity. At the core of an anti-money laundering program is that an institution must know its customers and the risks presented by its customers. The program becomes more difficult when the customer [...]
SEC Commissioner is a Blog Commenter
So you write a blog post about the fiduciary duty of financial service providers to their clients. Actually, the real story is about the lack of fiduciary duty that brokers have to their customers. Then an SEC Commissioner chimes in. Tara Siegel Bernard writes for New York Times blog, Bucks: Making the Most of Your [...]
Questions and Answers with Robert Khuzami
After the news conference announcing the Rearrangement of its Enforcement Program, the Securities and Exchange Commission offered a group of bloggers the chance to ask questions to Robert Khuzami, the Director of Enforcement. (It must have felt like Obi-Wan stepping into the cantina full of low-life scoundrels.) The blogging participants: Todd Sullivan of Value Plays [...]
SEC Rearranges its Enforcement Program
The Securities and Exchange Commission reorganized its enforcement division. Enforcement Director Robert Khuzami announced a new program announced the creation of new units. First, the SEC are expanding the whisteblower program. They are calling it a “cooperation program.” Then there are five new units in the enforcement division. Asset Management Unit The unit specializing in [...]
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