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Compliance Policies & Procedures

An example of a compliance policy and procedures
This P&P comes courtesy of Michelle Jacko, CEO of Core Compliance and Jacko Law Group in San Diego.
Consider that door closed. An attempt by Barclays to “open doors” by hiring the relatives and friends of foreign government officials in a bid to ...
Deficient trading reviews conducted by an inexperienced and untrained compliance associate has led to SEC charges that a New York-based broker-dealer published quotes and made ...
The very first line of the SEC settlement summary pulls no punches, offering words of caution to all private fund advisers. “Valuation of client assets ...
The brokerage industry certainly sees its fair share of movement of registered reps from one firm to the next and across financial services firms operating ...
John Brennan, head of technology at Highfields Capital Management in Boston gives us permission to share his IS policy as reprinted in the book, The ...
A CCO peer shares the table of contents from the advisory firm's compliance manual.
The commencement of OCIE’s “Cyber 3” initiative (IA Watch, March 27, 2018) is expected at any time now, but the specter of being caught in ...
Bill Sowell of Sowell Financial Services in North Little Rock, Ark., gives us permission to share with you his firm's document destruction P&P.
BKS Advisors had a compliance manual that included a “Block Order Allocation” policy aimed at preventing unfair trade allocations.  But that policy didn’t prevent long ...
Cross trading practices inconsistent with its compliance P&Ps, regulatory compliance manual and Forms ADV have yielded SEC charges against a New York-based investment adviser.   In ...
Jeffrey Davis, an Ameriprise rep based in Virginia, notified the dual registrant of the name of his outside business. Later, when Davis fraudulently sought to ...
A new settlement with an adviser first caught up in an OCIE sweep exam launched four years ago looking at wrap fee programs attests to ...
This matter concerns the failure of Ameriprise, a dually-registered investment adviser and broker-dealer, to adopt and implement policies and procedures reasonably designed to safeguard retail ...
This matter arises from Lockwood’s failure to adopt and implement policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules ...
Here's an example of a firm's compliance manual.
Mizuho Securities USA’s compliance training materials stressed the expectation of confidentiality concerning clients’ buyback order information. Slides during annual compliance training stated that “clients have ...
This is Janus Henderson Investors' best execution policy.
It is an oft-repeated refrain at industry conferences and in regulators’ speeches: fees and expenses of private equity fund advisers are a definite focus area ...
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