Posts in Policies and Procedures.
SEC Charges Morgan Stanley Smith Barney with Providing Misleading Information to Retail Clients

On May 12, 2020, the Securities and Exchange Commission (“SEC”) announced that Morgan Stanley Smith Barney (“MSSB”) agreed to settle charges that it provided misleading information regarding transaction costs and services to retail clients in its wrap program for the period from 2012 to 2017.

A Costly Failure to Follow Written Policies and Procedures

On November 22, 2019, the Securities and Exchange Commission ("SEC") ordered Channing Capital Management, LLC ("Channing"), a registered investment adviser located in Illinois, to pay a $50,000 civil penalty for failure to enforce its own written policies and procedures. This specific case underscores the importance of following the safeguards you put in place to protect all clients at all times.

Charging Fees for Inactive Accounts can be as Problematic as Churning

In a noteworthy action resulting from a lack of action in monitoring client accounts, the U.S. Securities and Exchange Commission ("SEC") fined three Raymond James entities $15 million for failing to conduct promised suitability reviews for certain advisory accounts invested in unit investment trusts ("UITs").

OCIE Risk Alert: Guidance for Compliance, Supervisory and Disclosure Procedures

The Office of Compliance Inspections and Examinations (OCIE) released a risk alert outlining findings of examinations it conducted as part of its Supervision Initiative...

While exchange-traded funds (ETFs), a hybrid investment product, have been a staple of modern investing since the early 90s, the Securities and Exchange Commission (SEC) has been slow to create a proper regulatory framework for this $3.4 trillion market....

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