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2011 CCOutreach Meeting
On February 8, FINRA and the SEC jointly presented the CCOutreach meeting for broker-dealers at the SEC offices in Washington, DC. This meeting is designed to allow CCOs and other compliance personnel from member firms to hear about important initiatives from the regulators and how other members deal with these matters. This meeting is free to attendees and is well worth the trip to Washington... |
By: Steve Sussman and Laura Crosby-Brown |
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Registration Requirement for California Placement Agents
There has been a lot of discussion lately surrounding placement agents and their possible need to register as lobbyists in various states. California set forth its requirements in the California Political Reform Act (CPRA), which became effective January 1, 2011. The CPRA requires placement agents soliciting business for external managers from the state’s public retirement systems (CalPERS and CalSTRS) to register as lobbyists...
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By: Katie Langridge |
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An Investment Adviser's Year-End Compliance Review
As investment advisers remain under an increasing amount of regulatory oversight by state and federal governments, many firms have wisely chosen to ramp up their compliance activities. Where the previous decade brought numerous financial scandals and unprecedented regulatory action by securities regulators and Congress alike, the financial services industry was dealt a punishing blow to its credibility... |
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2011 Examination Priorities
FINRA conducts about 2,300 cycle examinations each year to determine whether firms are in compliance with federal securities laws, rules and regulations. On February 9, Regulatory Compliance, LLC’s Compliance Partners account managers attended the 2011 FINRA Examination Priorities webinar presented by FINRA panelists. Below we've listed some of FINRA’s priority areas, along with summaries to assist...
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By: Kathryn Langridge and Jane Abramczyk
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Investment Adviser Compliance: Aggregating Orders
Aggregating orders (also called “bunched orders” or “block trades”) are common methods of executing equity orders for clients when the intent is to buy or sell the same equity for multiple clients. It may be attractive to aggregate trades for investors for the following reason: execution prices and/or commission rates may be more favorable... |
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New SEC Rules On Adviser Registration
On November 19, 2010, the Securities and Exchange Commission (the “SEC”) issued Investment Adviser Release Number IA-3111 (the “Release”) in which it proposed several rules to implement registration provisions under the Investment Advisers Act of 1940 (the “Advisers Act”), as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“The Dodd-Frank Act”). The mandate for implementation of the proposed rules resulted from repeal of Section 203(b)(3) of the Advisers Act... |
By: ©Geoffrey T. Chalmers, Esq. and Dalkis D. Muir, Esq.
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