Supervision

Firms will pay $1.1 million fine for having supervisory systems that were not reasonably designed to achieve compliance with Securities Act section 5

FINRA cautions that firms should recognize, and take action to address, red flags of improper unregistered distributions of securities

FINRA reveals that while a broker-dealer's WSPs delegated responsibility for reviewing manipulative trading alerts to compliance, the reviews weren't reasonable

Firm's supervisory system did not provide for a review or process to determine whether preliminary IPO prospectuses had been delivered successfully to institutional customers

"As chief compliance officer, [he] had 'overall responsibility for monitoring and testing compliance with the Firm’s policies and procedures'”

TSI and TSA breached their fiduciary duty to take reasonable steps to protect their clients’ interests from recognized material vulnerabilities to certain Models, which were ...

Beginning in 2024, the Carlyle Group and its investment adviser affiliates began to roll out on-channel messaging platforms for external communications

These off-channel communications included records required to be preserved under the Advisers Act because they related to a recommendation made or proposed to be made ...

The adviser lacked a process for reviewing the type of information shared with customers about agency CMO bonds and lacked any process for reviewing their ...

SEC settlement highlighted compliance review failures, the CCO's communications with a rep, and the ultimate resolution