... and update their internal policies to ensure that they provide appropriate guidance as to how to follow up, document, or report investigations regarding potential improper trading. US Securities and Exchange Commission (SEC) Enforcement Broker-dealers Investment advisers Compliance policies...

... and insufficient representations and disclosures, insufficient compliance policies and procedures, and insufficient research and oversight concerning the use of faulty quantitative models to manage certain client accounts. Design/methodology/approach Explains the SEC’s findings concerning the advisers...

... selected by using a consistently applied, objective, non-performance-based selection criterion, provided that certain additional requirements were met[ 3 ]. Compliance policies and procedures: Examples include advisers who did not implement policies and procedures pertaining...

... creation and distribution; and compensation practices. Findings – The report highlights areas that FINRA expects broker-dealers to consider in reviewing their compliance policies and procedures to assess whether firms should implement changes to their own conflict management frameworks. FINRA...

...Therese Pritchard; Jeff Kalinowski; Jeff Ziesman Purpose – The purpose of this paper is to remind investment advisers of the need for robust compliance policies and procedures in light of a recent SEC administrative proceeding in the case of IMC Asset Management, Inc. Design/methodology...