Investment Advisers

'We think the dissenting commissioners have it right that the proxy rule doesn’t seem to require what the order implies'

Mario Hernandez, CFP®, director of operations at Gemmer Asset Management in Walnut Creek, Calif., shares his firm's cyber P&P related to employee security roles. ...

Ahuja engaged in a fraudulent scheme to inflate the value of securities held by several private investment funds managed by Ahuja and Premium Point. The ...

The Commission staff’s investigation uncovered pervasive off-channel communications at all seniority levels at Cantor. The staff requested off-channel communications data from a sampling of more ...

The federal securities laws impose recordkeeping requirements on broker-dealers to ensure that they responsibly discharge their crucial role in our markets. The Commission has long ...

The firm failed to maintain and preserve off-channel communications its employees sent and received related to the broker-dealer’s business, CGMI received and responded to Commission ...

In September 2021, the Commission staff commenced a risk-based initiative to investigate whether broker-dealers were properly retaining business-related messages sent and received on personal devices. ...

Goldman Sachs’s widespread failure to implement its policies and procedures that prohibit such communications led to its failure to reasonably supervise its employees

Jefferies’ supervisors, who were responsible for preventing this misconduct among junior employees, routinely communicated off-channel using their personal devices

An associate on a derivatives trading desk exchanged more than 2,500 messages with Morgan Stanley colleagues, including several managing directors. The associate also texted with ...