FINRA Revives BrokerCheck Proposal
At the Financial Industry Regulatory Authority (“FINRA”) Board of Governors meeting held on February 13, 2014, a previously withdrawn rule change proposal was revived that would require brokerage firms to incorporate a link to “BrokerCheck” on their public websites and … Read More
SEC Charges Two Wall Street Traders Involved in Parking Scheme
On February 4, 2014, the Securities and Exchange Commission (“SEC”) announced charges against two traders involved in a “parking” scheme in which one trader temporarily placed securities in the other’s trading book in order to bypass a policy at his … Read More
Internal Control Oversights Charged to Trans-Atlantic Hedge Fund-Holding Company Partnership by SEC
In yet another case of negligence in regulatory internal controls, the Securities and Exchange Commission (SEC) sanctioned GLG Partners L.P., a UK-based hedge fund adviser, and its US-based holding company, GLG Partners Inc., with failure to implement the “proper controls” … Read More
New Anti-Money Laundering (AML) Rules Aim to Target Independent Advisers
Anti-money laundering (AML) regulation – currently applying only to broker-dealers – may soon affect independent advisers under a new proposal being currently drafted by the Financial Crimes Enforcement Network (FinCEN). First set forth as a proposed rule in 2003 and … Read More
SEC Releases Exemptive Order Guidance in Response to OIG Report
The Securities and Exchange Commission (SEC)’s Division of Investment Management released detailed guidance this month responding to compliance oversight findings issued in a report by the SEC’s Office of the Inspector General (OIG). The original OIG report, released on June … Read More
The Importance of Effectively Monitoring Gifts and Entertainment – Part 4: NASD
Last, but not least, another rule that firms should be aware of is NASD Conduct Rule 3060. This rule prohibits firms from giving any gift or gratuity in excess of $100 per year to any person where such payment is … Read More
The Importance of Effectively Monitoring Gifts & Entertainment – Part 3: Pay-To-Play
Another rule that firms must be mindful of in monitoring is the SEC’s, Pay-to-Play Rule. The Rule is designed to prevent investment advisers (IAs) from obtaining governmental business, through direct or indirect campaign contributions made by certain high-level employees to … Read More