Most of the time, the cases I write about were some other lawyer’s. In some respects, it’s easier to offer comments when it isn’t my case. I can, hopefully, be more objective, less pissed off (when the result is one I disagree with, of course), and content merely to mine the case for interesting lessons
Tell Me Something I Don’t Know: OCIE’s Tips To Surviving An SEC IA Exam
Let’s chalk this one up to “great minds think alike,” or maybe just “minds think alike.” You may recall that in his recent letter to member firms that accompanied FINRA’s 2017 Exam Priorities Letter, FINRA CEO Robert Cook said, “starting this year, we will publish a summary report that outlines key findings from examinations in…
Compliance Officer Liability: Findings Without Sanctions? The Plot Thickens
We have previously posted on the issue of CCO liability, a very sensitive subject, to say the least, for many readers of this blog. If this is a subject that interests you, then there was a very intriguing development this past week in this area that merits your attention.
It came in the form of…
SEC Advises Investment Companies and Registered Advisers to Formulate and Implement a Cybersecurity Plan
Obviously, given the name of this blog, the focus is on broker-dealers, but we also have a robust practice advising RIAs and investment management companies. In that vein, a group of attorneys working in our Cleveland office published a Client Alert today that discusses a recent Investment Management Guidance Update published by the SEC.