The Securities and Exchange Commission has been pointing out custody issues for investment advisers, made it an exam priority for 2014, highlighted in its presence exam initiative, and highlighted it in its never before examined initiative. So it should come as no surprise that the SEC brought an enforcement case solely for custody rule violations. … Read more »
Professional Ethics at the NRS Compliance Conference
These are my notes from the NRS Fall Compliance Conference. Dorothy (Dot) C. Kelly, Director, Training & Outreach for the Professional Conduct Program, CFA Institute Wendy L. Pirie, Director, Curriculum Projects, CFA Institute Robert Stirling, Senior Consultant, Investment Adviser Services, NRS According to the 2013 Edelman Trust Barometer, the Financial Services industry is the least … Read more »
Risk Management Panel at the NRS Compliance Conference
These are my notes from the NRS Fall Compliance Conference. Robert B. Hirth, Chairman, Committee of Sponsoring Organizations of the Treadway Commission Fred Shane, Chief Risk Officer, Commonwealth Financial Network Should CCOs be Taking on the Additional Role of a Chief Risk Officer? It Depends, of Course • Compliance requirements, degree of regulation, risk • … Read more »
Information Technology and Cybersecurity
These are my notes from the NRS Fall Compliance Conference. Ted Kobus, Baker Hostetler Karen M. Aavik, First Niagara Financial Group Tammy Eisenberg, CLS Bank International In 2012 the average cost of a data breach was $5.4 million. IBM 2014 Cost of Data Breach Study More breaches happen from lost laptops and media than third-party … Read more »
Supervision and the Urban Case, with Ted Urban
These are my notes from the NRS Fall Compliance Conference. Who better to talk about supervision than Ted Urban himself. He was the general counsel and chief compliance officer. One of the firm’s registered representatives went rogue. He and other line supervisors were charged by the SEC for failure to supervise. Urban pushed for the … Read more »
SEC Examination and Enforcement Priorities
These are my notes from the NRS Fall Compliance Conference. John Walsh, Sutherland Karol Pollock, SEC Deputy Associate Regional Director (Exams) Karol outlined the examination process. 1. You get a phone call. But prior to the phone call, the examiners will have done some background research, looking at the firms ADV, public website and an … Read more »
Regulatory Roundtable at the NRS Compliance Conference
These are my notes from the NRS Fall Compliance Conference Lance Burkett, District Director for FINRA Michelle Wein Layne, Regional Director for the SEC Andrew Hartnett, Securities Commissioner in Missouri and representing NASAA Each panel member went through list of enforcement and risk priorities that are currently high on their organization’s list. NASAA Broker Dealer … Read more »
Off to the NRS Conference
I’m off to sunny Scottsdale to attend my first NRS Fall Compliance Conference. If you are also attending, try to find me and I’ll buy you a cup of coffee (or at least head to the coffee urn with you). I’m speaking on Wednesday afternoon on Issues in Private Fund Management with John Walsh, from … Read more »
Weekend Reading: Countdown to Zero Day
We were in a cyber war with Iran. Kim Zetter unravels the story of Stuxnet, the US computer attack on Iran’s nuclear program in Countdown to Zero Day. A few months ago, I read A Time to Attack urging a US military attack on Iran. That book highlighted how Iran had been building a nuclear program … Read more »
Compliance Bricks and Mortar for October 24
These are some of the compliance-related stories that recently caught my attention. SEC Charges Athena Capital in First HFT Case in the Corporate Crime Reporter The Securities and Exchange Commission (SEC) has sanctioned a New York City-based high frequency trading firm for placing a large number of aggressive, rapid-fire trades in the final two seconds … Read more »