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CCO Liability
The CCO who admitted to the behavior received a $10,000 fine; the second—who didn’t cop to the backdating—got a $40,000 fine and a bar from ...
Rather than responding that he didn't have any records responsive to the staff’s request, Moors created three documents entitled Annual Compliance Calendars and purported to ...
The adviser erroneously billed and collected advisory fees on alternative investment positions, although no fees were supposed to be assessed on those positions
The most common alteration Ballek made to documents submitted to examiners was changing the dates the forms were signed by the portfolio manager or herself ...
Lessons that can be drawn from this case include to exercise extra scrutiny of trust accounts to ensure money isn’t being transferred illegally to an ...
Dual-hatted CCOs—often holding additional titles like president, CEO or principal—number about 20% of the population
It can pay to have checks and balances in place, but only if the check does the job thoroughly—especially if the monitor holds the title ...
"As chief compliance officer, [he] had 'overall responsibility for monitoring and testing compliance with the Firm’s policies and procedures'”
The lies ran as deep as a biblical flood. Wright allegedly told investors he put his own money into the investment. 'Wright had invested no ...
A battle royale shapes up between an adviser and the SEC over claims the firm’s CCO was both negligent and derelict in his duties, while ...









