Compliance Officer Barred for Audit Failures

Regulatory actions against compliance officers catch my attention. I don’t think compliance should be the target unless compliance engaged in the wrongdoing. I saw the action against Joseph Storms, identified as a “compliance associate” and dove in. Mr. Storms entered the securities industry as a compliance intern in 2005 with FINRA member firm Raymond James … Read more »

Compliance Bricks and Mortar for August 9

These are some of the compliance-related stories that recently caught my attention. Board Members Should Take Note — Delaware Supreme Court Issues Important Decision on Caremark Compliance Standardby Michael VolkovCorruption, Crime & Compliance The Delaware Supreme Court returned to this issue in a recent case – Marchand v. Barnhill et al, HERE, a case involving Blue Bell … Read more »

Revenue Sharing Disclosure Problems

The SEC charged Commonwealth Equity Services, LLC (d/b/a Commonwealth Financial Network), a registered investment adviser and broker-dealer, with failing to disclose material conflicts of interest related to revenue sharing Commonwealth received for certain client investments. According to the SEC’s complaint, Commonwealth had a revenue sharing agreement with its clearing broker for trades in their accounts. … Read more »

Compliance Bricks & Mortar for July 26

These are some of the compliance-related stories that recently caught my attention. Proskauer Launches Private Equity SEC Enforcement Tracker The tracker contains key information from the actions, including summaries of key issues, settlement terms, and relevant statutory provisions.  The tracker will be an important resource for us and our clients, providing us with quick access … Read more »

The Supervision Initiative

In 2017, the SEC’s Office of Compliance Inspections and Examination conducted exams of investment advisers that previously employed, or then currently employed, any individual with a history of disciplinary events. According to a just released Risk Alert, this was the Supervision Initiative. The initiative examined over 50 advisers, with a total of $50 billion in … Read more »