{"title":"2018年美国证券交易委员会的执法行动加强了对经纪交易商和投资顾问进行有效监管、政策和程序的重要性","authors":"Alec Koch, R. Ryan, Laura K. Bennett","doi":"10.1108/JOIC-02-2019-0014","DOIUrl":null,"url":null,"abstract":"\nPurpose\nTo provide analysis on several SEC enforcement actions of interest to broker-dealers and investment advisers.\n\n\nDesign/methodology/approach\nThe article is organized chronologically based on the dates of the SEC enforcement actions discussed.\n\n\nFindings\nThe SEC enforcement actions discussed in the article demonstrate that broker-dealers and investment advisers must maintain and enforce compliance and supervision policies and procedures reasonably designed to detect and prevent violations of the securities laws. When firm personnel commit violations (either intentionally or inadvertently), the SEC will evaluate whether firms could have been more effective in detecting and preventing those violations.Some of these cases also serve to remind firms that the SEC will often take enforcement action even when there is no evidence of customer harm.\n\n\nOriginality/value\nPractical guidance from experienced securities lawyers that consolidates and analyzes several recent SEC enforcement actions.\n","PeriodicalId":399186,"journal":{"name":"Journal of Investment Compliance","volume":"8 1","pages":"0"},"PeriodicalIF":0.0000,"publicationDate":"2019-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"0","resultStr":"{\"title\":\"2018 SEC enforcement actions reinforce the importance of effective supervision, policies, and procedures for broker-dealers and investment advisers\",\"authors\":\"Alec Koch, R. Ryan, Laura K. Bennett\",\"doi\":\"10.1108/JOIC-02-2019-0014\",\"DOIUrl\":null,\"url\":null,\"abstract\":\"\\nPurpose\\nTo provide analysis on several SEC enforcement actions of interest to broker-dealers and investment advisers.\\n\\n\\nDesign/methodology/approach\\nThe article is organized chronologically based on the dates of the SEC enforcement actions discussed.\\n\\n\\nFindings\\nThe SEC enforcement actions discussed in the article demonstrate that broker-dealers and investment advisers must maintain and enforce compliance and supervision policies and procedures reasonably designed to detect and prevent violations of the securities laws. When firm personnel commit violations (either intentionally or inadvertently), the SEC will evaluate whether firms could have been more effective in detecting and preventing those violations.Some of these cases also serve to remind firms that the SEC will often take enforcement action even when there is no evidence of customer harm.\\n\\n\\nOriginality/value\\nPractical guidance from experienced securities lawyers that consolidates and analyzes several recent SEC enforcement actions.\\n\",\"PeriodicalId\":399186,\"journal\":{\"name\":\"Journal of Investment Compliance\",\"volume\":\"8 1\",\"pages\":\"0\"},\"PeriodicalIF\":0.0000,\"publicationDate\":\"2019-07-01\",\"publicationTypes\":\"Journal Article\",\"fieldsOfStudy\":null,\"isOpenAccess\":false,\"openAccessPdf\":\"\",\"citationCount\":\"0\",\"resultStr\":null,\"platform\":\"Semanticscholar\",\"paperid\":null,\"PeriodicalName\":\"Journal of Investment Compliance\",\"FirstCategoryId\":\"1085\",\"ListUrlMain\":\"https://doi.org/10.1108/JOIC-02-2019-0014\",\"RegionNum\":0,\"RegionCategory\":null,\"ArticlePicture\":[],\"TitleCN\":null,\"AbstractTextCN\":null,\"PMCID\":null,\"EPubDate\":\"\",\"PubModel\":\"\",\"JCR\":\"\",\"JCRName\":\"\",\"Score\":null,\"Total\":0}","platform":"Semanticscholar","paperid":null,"PeriodicalName":"Journal of Investment Compliance","FirstCategoryId":"1085","ListUrlMain":"https://doi.org/10.1108/JOIC-02-2019-0014","RegionNum":0,"RegionCategory":null,"ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"","JCRName":"","Score":null,"Total":0}
2018 SEC enforcement actions reinforce the importance of effective supervision, policies, and procedures for broker-dealers and investment advisers
Purpose
To provide analysis on several SEC enforcement actions of interest to broker-dealers and investment advisers.
Design/methodology/approach
The article is organized chronologically based on the dates of the SEC enforcement actions discussed.
Findings
The SEC enforcement actions discussed in the article demonstrate that broker-dealers and investment advisers must maintain and enforce compliance and supervision policies and procedures reasonably designed to detect and prevent violations of the securities laws. When firm personnel commit violations (either intentionally or inadvertently), the SEC will evaluate whether firms could have been more effective in detecting and preventing those violations.Some of these cases also serve to remind firms that the SEC will often take enforcement action even when there is no evidence of customer harm.
Originality/value
Practical guidance from experienced securities lawyers that consolidates and analyzes several recent SEC enforcement actions.