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To explain the SEC's focus on the appropriate use of fee-based accounts and disciplinary efforts to identify and prevent “reverse churning.”

Describes the quantitative analytics used in the SEC's Risk Analysis Examinations (RAEs) to identify reverse churning and other problematic behaviors, explains why the inappropriate use of fee-based or “wrap fee” accounts and “double charging” can be unfair to investment clients, summarizes prior NASD and FINRA guidance and enforcement regarding fee-based account supervision, and recommends account monitoring actions that firms should take to ferret out reverse churning.

The SEC's continuing interest in reverse churning and double-charging, and its use of new examination and investigation tools, together suggest that the future will see more investigations and enforcement actions against firms who place clients in a fee-based or “wrap-fee” account without having adequate supervisory procedures to determine and monitor whether such accounts are appropriate for those clients.

Monitoring accounts to ferret out reverse churning has proven difficult for firms in the past, since spotting inactivity might be more challenging than detecting excessive trades (known as “churning”). However, it seems that the SEC and its staff are enhancing their ability to identify and address these violations.

Practical advice from experienced financial services lawyers.

Part I of this series appeared in the Summer 2002 issue of The Journal of Investment Compliance. It addressed the regulation of wrap fee programs under the Investment Company Act of 1940 (“Investment Company Act”) and the requirements of Rule 3a‐4 thereunder, which must be met so that a wrap fee program is not deemed to be an investment company. Part I also discussed certain issues arising under the Investment Advisers Act of 1940 (“Advisers Act”), including how program sponsors and any third‐party portfolio managers generally are viewed as investment advisers and are subject to the Advisers Act. Part II discusses additional Advisers Act issues such as suitability, fees, and advertising. It also briefly reviews issues arising under the Securities Exchange Act of 1934 (“Exchange Act”) and the Employee Retirement Income Security Act of 1974 (“ERISA”). The information provided in Part II assumes that readers have some basic familiarity with Part I.

To discuss and interpret the recently published summary of the select priorities of the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) in connection with the National Exam Program for 2015.

This article highlights the broad OCIE focus areas and provides detail on the associated initiatives.

OCIE’s priorities appear to place particular emphasis on retail investors and investors saving for retirement and market-wide risks, including cybersecurity. The examination priorities also emphasize OCIE’s evolving ability to analyze data to identify and examine registrants that may be engaged in illegal activity. Of particular interest to private equity fund sponsors, the National Exam Program will continue to conduct examinations that focus on fees and expenses borne by investors in private equity funds.

In view of the OCIE’s priorities, recent public comments by OCIE officials (concerning, for example, presentation of performance data) and our experience representing private equity firms being examined by OCIE, private equity fund sponsors should continue to be prepared for rigorous examinations on these issues and the areas of focus highlighted by the SEC in the past three years.

The article summarizes the OCIE’s recently published examination priorities for 2015 that cover a broad range of market participants and target a variety of their products, practices and procedures, including a continued focus on private equity fund sponsors.

The purpose of this paper is to examine the influence of institutional investors’ investment horizons (IIIH) on a wide variety of key corporate policies.

The authors perform regression analysis to a panel data set of quarterly financial statement data for US firms over the 1981-2014 using several measures of IIIH.

The authors argue that an increase in the presence of long-term investors contributes to more effective monitoring and information quality. This results in a reduction in agency costs and informational asymmetry problems for firms that are more heavily influenced by long-term investors, which in turn influences the corporate policies they pursue. Consistent with these arguments, the evidence suggests that firms with a greater long-term institutional investor base maintain lower investment outlays, higher dividend payments, lower levels of cash and higher levels of leverage. All results hold after controlling for potential endogeneity issues.

The authors show that a greater presence of long-term institutional investors leads to higher dividends, lower investment outlays, lower cash holdings and higher leverage. The comprehensive nature of the predictions with respect to overall corporate finance policies and the supporting evidence provided represents an important contribution, as previous studies have tended to focus on one specific area of corporate behavior (i.e. such as cash holdings).

Applied research shows higher wages are associated with lower mobility at the establishment level. A usual interpretation is that high pay decreases labour turnover. The purpose of this paper is to test if such relationship holds for every type of worker in every type of firm.

The analysis is based on a linked employer-employee panel dataset covering the French private sector from 2002 to 2005. The authors compute establishment wage effects and use them as explanatory variables in labour mobility equations (for churning rate and quit rate). Using spline regression models enables to investigate for potential non-linearities.

The authors show that the relationship between churning rate and wage is non-linear and has the shape of an inverted J: the relation is negative and intense for establishments with low wage effect, weaker for average paying establishments and even becomes positive for very high-paying ones. This is true whatever the skill group of workers. It is also true for large establishments while the relationship is still negative but linear for small ones. The relationship between wages and quit rates has a strikingly similar pattern. This suggests that the link between churning and establishment wage effect is strongly related to quit decisions.

A possible interpretation of our results is that paying higher wages may be an effective stabilizing tool especially for employers in small establishments and when starting wages are relatively low.

The paper is the first to decompose the relationship between wage and mobility. It shows the relationship differs across establishment size and is not linear. The paper also shows quits play a role in this relationship.

As acquiring new customers is costly, putting effort into satisfying and keeping customers over the long term can improve profitability. Firms usually do not know how each individual customer is feeling at any time (their attitude to the firm), so typically a customer's likelihood of leaving (“churning”) is predicted from behavioural data. The purpose of this paper is to investigate how a firm can add attitudinal variables to these churning models by deriving proxy indicators of satisfaction and commitment from behavioural data. The paper tests whether adding these proxies improved predictions of churning compared to a typical model based on purchasing behaviour (PB).

Analysing data from 6,000 regular customers from an Australian digital versatile disc rental company, logistic regression predicted membership termination (i.e. churning=1) versus continuation (=0). A baseline model used three traditional behavioural variables directly linked to members' PB. A second model including proxies for satisfaction and commitment from the customer database was compared against the baseline model to investigate improvement in churn prediction.

The most significant predictor of churn is an indicator of commitment: the uncertainty of a customer's commitment, indicated by number of times they changed their subscription plan.

The more customers change their plan, the more likely they are to quit the relationship with the firm, most likely because they are uncertain about how they can benefit from a long‐term commitment to the firm. Monitoring uncertainty indicators, such as plan changing, allows firms to intervene with special offers for uncertain customers, and, therefore, increase the likelihood of them staying with the firm.

The paper discusses the use of customer behaviour recorded in databases to identify proxy indicators of attitude before this attitude translates into churning behaviour.

The institution of food and cookery exhibitions and the dissemination of practical knowledge with respect to cookery by means of lectures and demonstrations are excellent things in their way. But while it is important that better and more scientific attention should be generally given to the preparation of food for the table, it must be admitted to be at least equally important to insure that the food before it comes into the hands of the expert cook shall be free from adulteration, and as far as possible from impurity,—that it should be, in fact, of the quality expected. Protection up to a certain point and in certain directions is afforded to the consumer by penal enactments, and hitherto the general public have been disposed to believe that those enactments are in their nature and in their application such as to guarantee a fairly general supply of articles of tolerable quality. The adulteration laws, however, while absolutely necessary for the purpose of holding many forms of fraud in check, and particularly for keeping them within certain bounds, cannot afford any guarantees of superior, or even of good, quality. Except in rare instances, even those who control the supply of articles of food to large public and private establishments fail to take steps to assure themselves that the nature and quality of the goods supplied to them are what they are represented to be. The sophisticator and adulterator are always with us. The temptations to undersell and to misrepresent seem to be so strong that firms and individuals from whom far better things might reasonably be expected fall away from the right path with deplorable facility, and seek to save themselves, should they by chance be brought to book, by forms of quibbling and wriggling which are in themselves sufficient to show the moral rottenness which can be brought about by an insatiable lust for gain. There is, unfortunately, cheating to be met with at every turn, and it behoves at least those who control the purchase and the cooking of food on the large scale to do what they can to insure the supply to them of articles which have not been tampered with, and which are in all respects of proper quality, both by insisting on being furnished with sufficiently authoritative guarantees by the vendors, and by themselves causing the application of reasonably frequent scientific checks upon the quality of the goods.

This study aims to investigate customers’ churning out of Internet Protocol Television (IPTV) service, one of the most prevalent forms of IT convergence.

Based on the review of current literature, a research model is introduced to depict the effects of select independent variables on customer churning behavior. First of all, the two groups are compared in terms of predictor variables, including switching barriers, voice of customer (VOC), membership period and degree of contents usage. Then, a curvilinear regression was applied to understand the association relationship between the level of IPTV contents usage and variables of switching barriers, VOC and membership period. Third, a logit regression was performed to predict customer churning through the variables of switching barriers, VOC, membership period and level of IPTV contents usage.

Through the empirical analysis, this study analyzed the factors affecting customer churning behavior of IPTV service providers based on switching barriers, VOC and contents usage.

Although several studies on IPTV have been undertaken globally, they have largely depended on self-reporting surveys to examine dynamics between antecedent variables and IPTV performance in terms of customer satisfaction, usage intension and customer retention. This empirical study is performed to understand influential factors of IPTV service defection through the weblog analysis of 3,906 service users, who represented both service defectors and non-defectors during a specific month.