NEWS & GUIDANCE
An easy out for many compliance staff given the duty to train firm employees on gifts and entertainment rules is to adopt the lowest regulatory threshold – FINRA’s $100 gift limit – within your P&Ps.   It’s simpler for staff to understand if you go with “the lowest common denominator,” suggests Medi...
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It’s been about one year since the SEC granted the first exemptive order to an adviser that had inadvertently violated the pay-to-play rule (IA Watch, Nov. 25, 2013). Now, the agency is poised to provide the second order relieving an adviser from the rule’s painful two-year time-out on receiving com...
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You’ve no doubt struggled with the SEC’s complex custody rule but nothing like Sands Brothers Asset Management ($64M in AUM) in New York. Its troubles with the rule – and SEC staff – date back another century.   This week the SEC announced another enforcement action against the adviser and the two b...
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