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CCO Liability
The Commission alleged that in 2013, as CCO, Ronald Heineman ignored red flags and engaged in a scheme to manipulate the price of a stock ...
Here are some preventative measures you can take to help prevent similar issues at your firm
The SEC’s pace of rulemaking in the last two years will challenge firms and CCOs, even as the Commission should lay out a “framework” to ...
"There are really three situations where the Commission typically brings enforcement actions against compliance personnel"
"It is unsurprising that many compliance professionals feel a sense of trepidation as to how the Commission will exercise its enforcement authority. Left with only ...
Greek myth meets regulatory reality in the case of an RIA that, like Icarus, aimed too high and fell back to Earth
As Summit’s sole owner and investment adviser representative, President, and Chief Compliance Officer, Richard Urciuoli was responsible for Summit’s failures
He failed to take necessary steps to do so despite being on notice of the rule’s requirements and was aware of the ongoing failures in ...
The CCO "did not review the offering materials or take other steps to determine whether her transfers were consistent with representations to CS Manager investors ...
The CCO pleaded guilty earlier this year