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CCO Liability

It doesn't always pay to listen to the boss
Settlement follows criminal case plea that could land the CCO in jail
Advisers systematically overbilled more than 100 of its client accounts for a total amount of over $11.8 million
RJ Advisers’ policies and procedures required FAs and the Compliance Department to monitor the Inactive Accounts. Specifically, FAs were to “continually monitor their client accounts,” ...
The CEO of a purported CPO/CTA met his future CCO in the same spot where the fraudster lured many of his investors: church.   The ...
Marconato made false statements to the NFA by denying the existence of his commodity pool
In a potentially worrisome case for compliance officers, the SEC found that the former CCO of Merrimac Corporate Securities had violated FINRA rules by providing ...
The potential liability of compliance officers may be waning, but there are still some egregious cases where mischief leads to deep trouble for a compliance ...
Regulatory change was flagged as the perceived single biggest challenge facing compliance officers this year, according to Thomson Reuters Regulatory Intelligence’s 10th annual survey on ...
On Behn’s recommendation, approximately 40 of Behn’s advisory clients invested more than $7 million in securities issued by Aequitas Commercial Finance, LLC (“ACF”), one of ...
The Commission’s amended complaint alleged that David Goulding allowed his father to use the Funds’ assets to pay personal expenses which were not supported by ...
For most of the Relevant Period, the RMC consisted of Deer Park’s Chief Compliance Officer, who was a former geochemist and brother-in-law of Portfolio Manager ...
Stephen Brandon Anderson obviously didn’t display a flair for the chief compliance officer role. That’s why a new settlement in an SEC enforcement action blocks ...
In September 2012, Anderson sent a letter notifying clients that River Source was raising its maximum annual advisory fee from 1.0% to 1.25% for clients ...
Rogers was the chief operating officer of Talimco and a member of the firm’s investment committee from 2012 until his separation from the firm in ...
SEC Commissioner Hester Peirce has picked up the mantle carried by former SEC Commissioner Dan Gallagher in openly supporting compliance staff (IA Watch, June 16, ...
The Commission’s complaint alleged that Respondent misappropriated at least $7.9 million from at least 15 investment advisory clients by perpetrating a Ponzi scheme in which ...
However it came about that you were named the CCO of your firm, you need to know the basics of what the Investment Advisers Act ...
Nadel fraudulently induced clients of RIA to invest tens of millions of dollars in what he falsely represented as a liquid, cash management investment program ...
In reality, Black Diamond managed no marketable assets at the time and has never met the minimum requirements for investment adviser registration with the Commission.
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