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CCO Liability
Williams, the firm’s CEO/CCO, 'failed to provide the Commission with evidence to corroborate' the Form ADV filing claiming trillions in AUM
Vista and Ruben Cedrick Williams falsely claimed in the adviser's Form ADV filing that the firm had $10B in AUM and then stating its AUM ...
Collett did not reconcile the block trade tickets to the trade log to ensure that the block trades were properly allocated. Instead, Collett trusted that ...
The case helps to define that sometimes squiggly line around CCO liability, and conjures advice for how a CCO should act when her superior shows ...
The Commission alleged that in 2013, as CCO, Ronald Heineman ignored red flags and engaged in a scheme to manipulate the price of a stock ...
Here are some preventative measures you can take to help prevent similar issues at your firm
The SEC’s pace of rulemaking in the last two years will challenge firms and CCOs, even as the Commission should lay out a “framework” to ...
"There are really three situations where the Commission typically brings enforcement actions against compliance personnel"
"It is unsurprising that many compliance professionals feel a sense of trepidation as to how the Commission will exercise its enforcement authority. Left with only ...
Greek myth meets regulatory reality in the case of an RIA that, like Icarus, aimed too high and fell back to Earth