Thursday, May 26, 2016

FINRA and SEC Actions Against Compliance Officers

There was a time when FINRA and the SEC, gave compliance officers a pass in regulatory actions, except of course in the most egregious cases. Their job is tough enough without worrying about a regulatory complaint because of perceived mis-step by someone at their firm.

Those days are gone, and the first line of regulatory oversight at the 4,000+ brokerage firms in this country is finding itself the subject of regulatory proceedings. Fortunately, we have not seen many actions against compliance officers, and the reality is that a good faith effort to create a supervisory system, and to insure that it is being followed, should keep the compliance department out of a regulatory action.

But it does happen, and Brian L. Rubin from Sutherland Asbill and Brennan, LLP, has put together an analysis and recap of recent enforcement proceedings against compliance officers.