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
On November 18, 2015, SEC Chair Mary Jo White gave testimony to the Committee on Financial Services, outlining the various steps the SEC has been taking and what they plan on doing going forward in regards to the financial markets … 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
In every walk of life, manual functions are being automated and securities compliance is no exception. This trend will likely continue, and for good reason: automation can create efficiency, improve accuracy and increase capacity. In this update we will address some of … 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
