Journal of Investment Compliance: Volume 16 Issue 1

Recent civil and criminal enforcement action involving high frequency trading

Matthew Rossi, Greg Deis, Jerome Roche, Kathleen Przywara

– To alert high frequency trading firms to the increased regulation and prosecution of manipulative trading practices during 2014 and early 2015.

Recent key Bitcoin and virtual currency regulatory and law enforcement developments

Evan L. Greebel, Kathleen Moriarty, Claudia Callaway, Gregory Xethalis

– To explain and draw conclusions from six recent bitcoin and virtual currency regulatory and law enforcement developments.

Securities and Exchange Commission announces enforcement initiative directed at reporting violations by public company insiders

Richard J. Parrino, Peter Romeo, Alan Dye

The purpose of this paper is to review the enforcement initiative announced by the US Securities and Exchange Commission (SEC) in September 2014 directed at reporting violations…

US SEC approves sweeping amendments to rules governing money market funds

Jack Murphy, Stephen Cohen, Brenden Carroll, Aline A. Smith, Matthew Virag, Justin Goldberg

To explain the background and details and to discuss the implications of the USA Securities and Exchange Commission’s (SEC’s) July 23, 2014 amendments to Rule 2a-7 and other rules…

Useless/redundant/unread information returns and protective filings

Roger Lorence

To describe the best practices for complying with the increasingly large body of information returns required by the Internal Revenue Service of participants in the investment…

Prepare for the magnifying glass: SEC hikes scrutiny of asset managers – 4 steps to consider

Perrie Michael Weiner, Patrick Hunnius, Grant Alexander

To discuss the Securities and Exchange Commission’s (SEC’s) likely preparation of new rules to increase the monitoring and oversight of various asset funds, including hedge funds…

What does it take to make the SEC happy? SEC criticism of broker-dealers’ due diligence for sales of unregistered securities leaves more questions than answers

Bruce Bettigole, Charlie Kruly

To highlight the insufficient guidance offered by a recent Securities and Exchange Commission settlement regarding a broker-dealer’s obligation to inquire into its customers’…

SEC charges broker-dealer for failure to protect against insider trading by employees

Daniel A. Nathan, Tiffany Rowe

To alert broker-dealers to Securities and Exchange Commission charges brought against a broker-dealer for ineffective controls over employee use of confidential information and to…

SEC issues Staff Legal Bulletin after four-year comprehensive review of proxy system

John E. Sorkin, Abigail Pickering Bomba, Steven Epstein, Jessica Forbes, Peter S. Golden, Philip Richter, Robert C. Schwenkel, David Shine, Arthur Fleischer, Gail Weinstein

To provide an overview of the guidance for proxy firms and investment advisers included in the Staff Legal Bulletin released this year by the Securities and Exchange Commission…

Expense allocation: the SEC brings down the hammer

Kenneth Berman, Gregory Larkin, Phil V. Giglio, Erica Berthou, Michael P. Harrell, Jordan C. Murray, Jaime D. Schechter, Geoffrey Kittredge

– Describe an important recent enforcement action by the Securities and Exchange Commission (SEC) regarding expense allocations by private equity funds.

CFTC clarifies and expands relief relating to delegation of commodity pool operator responsibilities

Cary Meer, Lawrence B. Patent

To explain CFTC No-Action Letter 14-126, issued on October 15, 2014 by the Commodity Futures Trading Commission Division of Swap Dealer and Intermediary Oversight, which sets…

FATCA violation underlies latest US tax and securities fraud charges

Miriam Fisher, Brian McManus

To explain the details and implications of a September 9, 2014 federal indictment, US v. Robert Bandfield, the first time a Foreign Account Tax Compliance Act (FATCA) violation…

SEC touts whistleblower award to a compliance professional – use care in responding to reports of potential violations

Mark Srere, Mary Beth Buchanan, Elaine Koch, Jennifer Mammen, Tyson A. Johnson

– To highlight the first award granted under the US Securities and Exchange Commission Whistleblower Program to a compliance professional.

Editor's letter

Henry A Davis