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What Are the Hallmarks of a Strong Compliance Program?

December 26, 2013

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I thought it would be interesting to hear it from the horse’s mouth once more. Speaking before the Society of Corporate Compliance and Ethics’ 12th Annual Compliance & Ethics Institute, Stephen L. Cohen, the SEC’s Associate Director of Enforcement, laid out what makes a good compliance program. Among the hallmarks of a “robust” compliance program, […]

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FINRA Cracking Down on “No Fee” Advertising

November 29, 2013

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FINRA recently expressed concerns about broker-dealers who advertise “free” or “no fee” services for retail brokerage accounts and individual retirement accounts (IRAs). FINRA Rule 2210 requires that broker-dealers’ communications are fair and balanced and do not omit material information that would cause them to be misleading. FINRA is concerned about transparency.  Broker-dealers’ marketing campaigns often […]

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SEC Examinations Targeting Advisers Who Are Still Waiting for Godot

November 19, 2013

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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 existence. That may be a thing of the past. They will be the focus of the SEC in 2014, according to Andrew Boden, head of the SEC’s Office […]

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Three Steps to an Effective Whistleblower Program

November 16, 2013

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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 recently made to a whistleblower who helped to uncover investment fraud.  Violations of securities laws are only one aspect of illegal behavior that should be covered by your […]

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