“I don’t measure a man’s success by how high he climbs but how high he bounces back when he hits the bottom.” ~General George Patton As another year is quickly coming to a close, so often organizations reflect on metrics … Read More
A Different Perspective On November 30, 2015, SEC Commissioner Luis Aguilar published “Commissioner Aguilar’s (Hopefully) Helpful Tips for New SEC Commissioners.” What follows is an application of a portion of Commissioner Aguilar’s advice geared for a new Chief Compliance Officer … Read More
All compliance officers are de facto project managers. Whether you are conducting an internal audit, authoring and implementing policies and procedures, rolling out new compliance technology, or training employees on compliance requirements – all these projects go towards helping your … Read More
In her testimony yesterday before the Committee on Financial Services of the United States House of Representatives SEC Chair Mary Jo White shared the following regarding third-party compliance reviews: At my direction, the staff is also preparing a recommendation to … Read More
On November 16, 2015, the Securities and Exchange Commission (“SEC”) issued administrative and cease and desist proceedings against Virtus Investment Advisers, Inc. (“Virtus”) for marketing a “materially inflated, and hypothetical and back-tested, performance track record” of one of its sub-advisers, … Read More
Unauthorized Access Cybersecurity is essentially a regime to prevent unauthorized access. Authorized users are authenticated most commonly via a username and password. However, requiring just a password with a username for access is considered a weak protection control. Weak because … Read More
On October 22, 2015, the Securities and Exchange Commission (“SEC”) released information on the enforcement cases they’ve brought during their 2015 fiscal year, which ended on September 30, 2015. The results as compared to 2014, including an additional 52 cases … Read More
On October 8, 2015, the Securities and Exchange Commission (“SEC”), approved changes to Financial Industry Regulatory Authority, Inc. (“FINRA”) Rule 2210 requiring FINRA member firms that have retail clients to include a link to FINRA’s BrokerCheck on their websites. BrokerCheck … Read More
Majority Opinion of the Commission On October 2, 2015, the Securities and Exchange Commission (“SEC”) issued an Opinion of the Commission in the matter of Raymond J. Lucia Companies, Inc. and Raymond J. Lucia, Sr regarding the backtested performance of … Read More
Recently, the Securities and Exchange Commission (“SEC”) charged Focus Media Holding Limited (“Focus”) and its CEO, Jason Jiang, with surrounding the partial sale of a subsidiary. According to the press release, the China-based company and Jiang” violated an antifraud provision … Read More