Carl Ayers
The final rule states that human-directed 'client-specific investment advice, even if delivered through electronic means, would not be eligible activity under the Internet Adviser Exemption'
Senvest failed to implement procedures to monitor whether its employees were following the firm’s policies concerning work-related communications .... At least three senior Senvest officers ...
"The rule’s invocation of the term 'material' is a red herring"
"Rules of such broad effect should be set by the full Commission, not by staff answering only to the Chairman"
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"I was surprised to learn when I came to the SEC that the Commission actually didn’t have its own best execution rule"
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March proved to be a tough month for the SEC in two federal courts. One judge accused the Commission of “gross misconduct” and, in a ...
Here are some preventative measures you can take to help prevent similar issues at your firm
With mergers and acquisitions continuing apace in the industry, know that CCOs can play a key role whenever an advisory ownership change occurs