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...
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...
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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