Finding A Way.

SAC Capital, Insider Trading and the Southern District

It would be old news already if the case had not garnered so many superlatives.  One of the country’s most famous hedge fund managers.  The largest insider...

SEC Examinations Targeting Advisers Who Are Still Waiting for Godot

I have worked with a number of advisers who have never ever been examined by the SEC, not once in their 10 +, 15+, etc. years of...

Three Steps to an Effective Whistleblower Program

Everyone should have one. If you need more convincing, please read my post, or any post for that matter, about the record $14 million award the SEC...

FINRA’s Conflicts of Interest Report: Bridging the Great Divide?

FINRA issued a report on conflicts of interest within the broker-dealer industry last month.  It is the result of a review initiated in July 2012 at a...

The SEC and the Chief Compliance Officer, 2013

Mary Jo White recently gave a speech before the National Society of Compliance Professionals that I found noteworthy.  It focused on the role of the Chief Compliance...

SEC Brings First Action Under Chief Compliance Officer Rule

The SEC recently sanctioned a former portfolio manager  under Rule 38a-1(c) of the Investment Company Act, which prohibits misleading and obstructing a chief compliance officer (CCO).  Carl...

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