Does Your Firm Have a Handle on Its Insider Trading Risks?

It’s the cardinal rule for investment professionals: Do not use, share, disseminate or trade on the basis of material, non-public information. Even so, the SEC regularly charges brokers, advisors and other industry insiders with illegal insider trading. Of course,...

Does Your Firm Need a Formal “Conflicts of Interest” Program?

Anyone involved in the compliance function for a financial services firm knows they need to be mindful of, and watchful for, potential conflicts of interest – whether real or perceived. Likewise, for example, CCOs at firms subject to the DOL’s Fiduciary Rule know that...

Creating a Culture of Compliance

The idea of establishing a “culture of compliance” in financial services firms isn’t a new idea; firm CCOs have heard regulators touting the standard for decades. However, a seemingly endless parade of firms continues to be cited for compliance violations that seem to...

What Do Your Regulatory Filings Say about You?

For investors who are paying attention, staying on top of companies’ annual reports, 10-Q and 10-K regulatory filings and incorporating changes into trading decisions may help yield significantly higher overall returns than overall market performance. Reported data on...

Understanding the SEC OCIE’s Focus on Trading Activities

For SEC-regulated entities, understanding the approach the commission’s Office of Compliance Inspections and Examinations (OCIE) takes may help firms better prepare when the regulators come calling. Each year, OCIE’s published examination priorities give firms a road...

Is Your Firm in Compliance with Pay-to-Play Rules?

Firms engaged in the financial services industry in the U.S. are likely subject to at least one of several “pay-to-play” rules, designed to regulate political contributions by firms or their personnel. The intent of each of the rules is the same: to prohibit firms, or...