SEC Charges GE Funding Capital Market Services with Fraud Involving Municipal Bond Proceeds

The SEC charged GE Funding Capital Market Services with securities fraud for participating in a wide-ranging scheme involving the reinvestment of proceeds from the sale of municipal securities. They agreed to settle the charges by paying approximately $25 million, which will be returned to affected municipalities or conduit borrowers. The firm also entered into agreements with the Department of Justice, Internal Revenue Service, and a coalition of 25 state attorneys general and will pay an additional $45.35 million. In addition to fraudulently manipulating bids, GE Funding CMS made improper, undisclosed payments to certain bidding agents in the form of swap fees that were inflated or unearned. These payments were in exchange for the assistance of bidding agents in controlling and manipulating the competitive bidding process.

The settlements arise from extensive law enforcement investigations into widespread corruption in the municipal reinvestment industry. In the past year, federal and state authorities have reached settlements with four other financial firms, and 18 individuals have been indicted or pled guilty, including three former GE Funding CMS traders.

For a list of other financial institutions charged prior to the settlement with GE Funding CMS follow the link below.

SEC Charges GE Funding Capital Market Services with Fraud Involving Municipal Bond Proceeds

Judge Orders Plastics Executive to Pay $49.5 Million in SEC Case

The SEC has announced the successful resolution of its trial against a plastics industry executive charged with lying in SEC filings regarding his ownership of Musicland Stores Corporation stock. The executive and a trust he controlled have been ordered by a federal judge to pay $49.5 million in a final judgment against them. The executive failed to file truthful 13D forms and neglected to make other required filings, which are required when a person acquires beneficial ownership of more than 5 percent of a voting class of a company's publicly traded stock. Because of this the execute and the trust thereby materially misrepresented their ownership of Musicland stock.

Following a 10-day trial in May in federal court in Newark, N.J., a jury returned a verdict finding the executive liable for securities fraud and disclosure violations on all counts against him. The jury also found the MAAA Trust controlled by him liable for disclosure violations.

Judge Orders Plastics Executive to Pay $49.5 Million in SEC Case

SEC Adopts Net Worth Standard for Accredited Investors Under Dodd-Frank Act

The SEC has amended its rules to exclude the value of a person’s home from net worth calculations. These calculations are used to determine whether an individual may invest in certain unregistered securities offerings. The changes were made to conform the SEC’s definition of an “accredited investor” to the requirements of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act.

SEC Adopts Net Worth Standard for Accredited Investors Under Dodd-Frank Act

SEC Adopts Dodd-Frank Mine Safety Disclosure Requirements

The SEC has adopted new rules outlining how mining companies must disclose the mine safety information required by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under Section 1503 of the Dodd-Frank Act, mining companies are required to include information about mine safety and health in the quarterly and annual reports they file with the SEC. The Dodd-Frank Act disclosure requirements are based on the safety and health requirements that apply to mines under the Federal Mine Safety and Health Act of 1977, which is administered by the Mine Safety and Health Administration (MSHA). To read the full rules, follow the link below.

SEC Adopts Dodd-Frank Mine Safety Disclosure Requirements

SEC Charges Executives at Clean Coal Technology Company for Misstatements to Investors

The SEC charged the former CEO and CFO at a Minnesota-based clean coal technology company for making false and misleading statements to investors. The SEC separately charged a network of brokers who sold the company’s securities without being registered with the SEC to do so. Bixby Energy Systems raised at least $43 million from more than 1,800 investors through a series of purported private placement offerings of stocks, warrants, and promissory notes during a nine-year period. The company used this capital raising activity to help fund operations, pay salaries, and pay commissions to brokers that sold Bixby securities.

The SEC alleges that Bixby’s former CEO and former CFO made repeated misstatements both verbally and in writing to investors about the company’s core product – a machine that supposedly produced synthetic natural gas through a proprietary clean coal technology. They told investors that Bixby’s coal gasification machine was proven and operating when in fact it had substantial technological defects, did not function properly, and was at risk of self-destruction. The CEO and CFO never disclosed these problems to investors.

SEC Charges Executives at Clean Coal Technology Company for Misstatements to Investors

SEC Charges California Company, Co-CEOs, and Attorney in Series of Fraudulent Schemes Pumping Company Stock

The SEC charged a purported heart monitoring device company and six individuals involved in a series of fraudulent schemes to artificially inflate the company’s stock. Among those charged are a former pro football player and a former Hollywood executive who were co-CEOs of Heart Tronics. An attorney who masterminded the scheme and brought in nearly $8 million in secret trades was also charged.

In addition to Heart Tronics, and the three individuals, the SEC charged three other individuals involved in the scheme, including the attorney ’s chauffeur and handyman , who carried out the fraud with him. The SEC also charged a stock promoter, as well as the trustee and stockbroker for a number of nominee accounts that the attorney used to unlawfully sell Heart Tronics stock.

In a parallel criminal investigation, the U.S. Department of Justice today announced the arrest of the attorney.

SEC Charges California Company, Co-CEOs, and Attorney in Series of Fraudulent Schemes Pumping Company Stock

SEC Charges Longtime Madoff Employee with Falsifying Documents to Deceive Regulators

The SEC charged a longtime Bernie Madoff employee with falsifying books and records in order to hide Madoff’s fraudulent investment advisory operations from regulators.

The SEC alleges that the employee, who worked at Bernard L. Madoff Investment Securities LLC (BMIS) for more than 30 years, assisted in falsifying BMIS’s internal accounting records in order to misclassify hundreds of millions of dollars of income purportedly generated by BMIS’s investment advisory operations. The employee also falsified financial statements filed with the SEC and other regulators, as well as materials that were prepared to deceive SEC staff examiners, federal and state tax auditors, and other external reviewers.

“To keep his massive fraud alive, Madoff had to hide as many facts about his advisory operations as possible,” said George S. Canellos, Director of the SEC’s New York Regional Office. “Cotellessa-Pitz along with other senior BMIS personnel played a critical role in this effort by creating false documents to deceive federal and state regulators.”

The SEC previously charged BMI's Director of Operations with falsifying books and records to hide and obfuscate Madoff’s advisory operations. According to the SEC’s complaint against the employee, she played a central role in falsifying these records as directed by Madoff and the Director of Operations. Madoff used the false records to artificially improve the firm’s reported revenue and income as well as to deceive regulators who sought to review the firm’s operations and financial results.

SEC Charges Longtime Madoff Employee with Falsifying Documents to Deceive Regulators

SEC Charges Former Fannie Mae and Freddie Mac Executives with Securities Fraud

The SEC has charged six former top executives of the Federal National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie Mac) with securities fraud, alleging they knew and approved of misleading statements claiming the companies had minimal holdings of higher-risk mortgage loans, including subprime loans.
Fannie Mae and Freddie Mac each entered into a Non-Prosecution Agreement with the Commission wherein each company agreed to accept responsibility for its conduct and not dispute, contest, or contradict the contents of an agreed-upon Statement of Facts without admitting nor denying liability. Each also agreed to cooperate with the Commission's litigation against the former executives.
"Fannie Mae and Freddie Mac executives told the world that their subprime exposure was substantially smaller than it really was," said Robert Khuzami, Director of the SEC's Enforcement Division. "These material misstatements occurred during a time of acute investor interest in financial institutions' exposure to subprime loans, and misled the market about the amount of risk on the company's books. All individuals, regardless of their rank or position, will be held accountable for perpetuating half-truths or misrepresentations about matters materially important to the interest of our country's investors."
SEC Charges Former Fannie Mae and Freddie Mac Executives with Securities Fraud

SEC Halts Father-Son Ponzi Scheme in Utah Involving Purported Real Estate Investments

The SEC charged a father and son in Utah with securities fraud for selling purported investments in their real estate business that in reality was just a $220 million Ponzi scheme.

It is alleged that the father and son operated from a base in Fountain Green, Utah. They offered investors the opportunity to invest in LLCs to share ownership of large apartment complexes in eight states. The investors were solicited by word of mouth and through religious affiliation. The duo presented plans to buy apartment complexes, renovate and revamp, and then sell for a high profit. The investors were told they would share in the profit from the sales and also from rental income. The truth of the matter was that the investors money was really being depositing into large bank accounts, which were used for company and personal expenses, and to pay other investors. Since the complaint has been filed, the SEC obtained an emergency court order freezing the father and son's assets and companies. The scheme began in 2008 and involved 225 investors and more than $220 million.

SEC Halts Father-Son Ponzi Scheme in Utah Involving Purported Real Estate Investments

SEC Charges Options Trader for Illegal Short Selling Tactics

An options trader in the Chicago area has been charged by the SEC with violating short selling restrictions when he failed to locate and deliver the shares involved in short sales to broker-dealers and their institutional customers. He has agreed to pay more than $2 million to settle the SEC’s charges.

George S. Canellos, Director of the SEC's New York Regional Office said, “[he] avoided the cost of borrowing shares while engaging in complex short selling transactions, thus earning significant profits with minimal risk and gaining an advantage over legitimate participants in the market. We’ll continue aggressively to pursue and punish abusive short sellers who attempt to circumvent regulatory requirements to make more money.”

SEC Charges Options Trader for Illegal Short Selling Tactics

SEC Charges Seven Former Siemens Executives with Bribing Leaders in Argentina

Seven former Siemens executives have been charged by the SEC with violating the Foreign Corrupt Practices Act (FCPA) for their involvement in the company's decade-long bribery scheme to retain a $1 billion government contract to produce national identity cards for Argentine citizens. Siemens has previously been charged with FCPA violations by the SEC and has already paid $1.6 billion to resolve those charges.

The SEC alleges that the executives who maintained the scheme worked at Siemens and its regional company, Siemens Argentina. Siemens paid more than $100 million in bribes to such high-ranking officials as two former Argentine presidents and former cabinet members. The executives falsified documents and participated in meetings in the United States to negotiate the terms of bribe payments. In a parallel criminal action, the Department of Justice announced charges against former executives and agents of Siemens. They are charged with conspiracy to violate the FCPA and the wire fraud statue and wire fraud.

SEC Charges Seven Former Siemens Executives with Bribing Leaders in Argentina

SEC Charges "Shell Packagers" and Several Others in Penny Stock Scheme

The SEC alleges that Belmont Partners LLC and its President utilized fabricated and backdated documents to convince a transfer agent and an attorney writing an opinion letter to issue free-trading shares of Alternative Green Technologies Inc. (AGTI). The SEC also charged AGTI, its CEO, a business partner and stock promoters for their roles in the scheme that resulted in unknowing investors purchasing fraudulently issued AGTI shares without the protections afforded by the securities laws.

“Shell packagers who buy and sell public companies for use by fraudsters have no rightful place in our markets,” said David Rosenfeld, Associate Director of the SEC’s New York Regional Office. “These shell packagers not only sold the shell company, but created the false documents necessary to cause the transfer agent to issue shares that should never have been sold to the public.”

According to the SEC’s complaint, false documents were submitted to a transfer agent and an attorney, who relied on them to conclude that free-trading shares of AGTI could legitimately be issued. The fraud was aided by Belmont Partner and their CEO creating and sometimes backdating the false documentation, including a sham assignment of debt and a fabricated and backdated corporate resolution and convertible note. Then AGTI's CEO then used the illegally issued stock certificates to fund promotional campaigns promoting their stock. The stock promoters were charged with selling the unregistered securities.

SEC Charges "Shell Packagers" and Several Others in Penny Stock Scheme

SEC Enforcement Director's Statement on Citigroup Case

The SEC’s Director of the Division of Enforcement, Robert Khuzami, made the following statement on the Citigroup case:

Last month, a federal district court declined to approve a consent judgment because, in its view, the underlying allegations were ‘unsupported by any proven or acknowledged facts.’ As a result, the court rejected a $285 million settlement between the SEC and Citigroup that reasonably reflected the relief the SEC would likely have obtained if it prevailed at trial.

We believe the district court committed legal error by announcing a new and unprecedented standard that inadvertently harms investors by depriving them of substantial, certain and immediate benefits. For this reason, today we filed papers seeking review of the decision in the U.S. Court of Appeals for the Second Circuit..."

The full statement can be found at: SEC Enforcement Director's Statement on Citigroup Case

Jon Corzine, Bernie Madoff, And Why The SEC Should Directly Regulate Investment Advisors - Forbes

I have certainly been critical of FINRA in the past, and it certainly makes its share of mistakes, but this piece in Forbes is a bit aggressive and over the top.
The argument here is that because FINRA did not catch Madoff, and gave Corzine a waiver on his securities examinations, the SEC should regulate investment advisors. That, with all due respect to Forbes and the author, makes no sense.
First, let's be clear. My firm belief is that the SEC should regulate investment advisors, and I am even firmer in my belief that FINRA should not be allowed anywhere near investment advisors. That being said, the Forbes article is off base for a couple of reasons.
First, the SEC IS the entity that is responsible for regulating investment advisors, at least those with in excess of 30 million dollars under management.
Second, using Madoff as an example is not such a great example, since the SEC was the regulator with primary responsibiltiy for oversight of Madoff - the fraud occured for the most part at his investment advisory firm, which was regulated by the SEC, not FINRA.
And third, we are going argue against FINRA as a regulator because it waived examinations for Corzine? Really? I can think of at least a dozen reasons not to give FINRA oversight of investment advisors - waiving the examinations for Corzine, while a terrible move both on an regulatory and public relations front, is not in the top 20 reasons to deny them that authority.
At the top, FINRA tries. Its executives talk a good game, but they are terrible at getting their message down to the staff, who still, in far too many instances, treat brokers and firms as if they are criminals, conducting exams with a "gotcha!" mentality, and constantly looking for the "career making" error in every examination they conduct. It is absurd, and not good regulatory policy. The Corzine incident was an embarrassment. The forging of documents during an SEC investigation is unforgiveable, and would result in a permant bar from the industry if a brokerage firm executive pulled such a stunt.
And, lets keep in mind that although you would never know it from dealing with them, FINRA is a membership organization, it is owned, operated and controlled by the big firms. Independent broker-dealers and investment advisors are NOT part of that association, and are competitors to the brokerage industry. In fact, I would imagine that many of the executives in the investment advisory world went to that side of the industry to get away from the very issues that FINRA cannot shake - it is owned, lock, stock and barrell by the large firms.
In what other industry would a regulated entity be permitted to continue in operations with tens of millions of dollars in fines, with multiple, systemic violations, year after year? That could only occur when the regulated entity is in control of the regulator.
We don't need FINRA expanding its power and authority over yet another facet of the financial industry, increasing its ability to quash competition. If we want sound regulatory oversight, it needs to come from an independent entity, not one that would love to see the regulated put out of business.
Jon Corzine, Bernie Madoff, And Why The SEC Should Directly Regulate Investment Advisors

SEC Charges GlaxoSmithKline Subsidiary and Former CEO With Defrauding Employees in Stock Plan

Stiefel Laboratories Inc is a subsidiary of pharmaceutical company GlaxoaSmithKline and was the world's largest private manufacturer of dermatology products. The SEC alleges that the subsidiary omitted information from employees and lead them to believe their stock was worth much less than it truly was. They then bought back the stock for a greatly undervalued price.

Stiefel Labs purchased more than 750 shares of company stock from shareholders between November 2006 and April 2007 at a price of $13,012 per share. Stiefel Labs' CEO knew that five private equity firms had submitted offers to buy preferred stock in November 2006 based on equity valuations of Stiefel Labs that were approximately 50 to 200 percent higher than the valuation later used for stock buybacks. There were also an additional 1,150 shares that were bought between July 2007 - June 2008 and Dece 2008 - April 2009.

SEC Charges GlaxoSmithKline Subsidiary and Former CEO With Defrauding Employees in Stock Plan

Joint Statement on Regulation of OTC Derivatives Markets

The SEC and other regulators released the following statement:

"Leaders and senior representatives of the authorities responsible for regulation of the over-the-counter (OTC) derivatives markets in Canada, the European Union, Hong Kong, Japan, Singapore, and the United States met yesterday in Paris.

The meeting included Steven Maijoor, Chair of the European Securities and Markets Authority (ESMA); Jonathan Faull, Director General for Internal Market and Services at the European Commission; Ashley Alder, Chief Executive Officer of the Hong Kong Securities and Futures Commission; Masamichi Kono, Vice-Commissioner of the Japan Financial Services Agency; Teo Swee Lian, Deputy Managing Director (Financial Supervision) of the Monetary Authority of Singapore; Mary Condon, Vice-Chair of the Ontario Securities Commission; Louis Morisset, Superintendent of Securities Markets at l’Autorité des Marchés Financiers du Québec; Gary Gensler, Chairman of the United States Commodity Futures Trading Commission; and Mary Schapiro, Chairman of the United States Securities and Exchange Commission.

Since mid-2011, the authorities have engaged in a series of bilateral technical dialogues on OTC derivatives regulation. The meeting, held at ESMA headquarters in Paris, is the first time the authorities have met as a group to discuss their implementation efforts.

In the meeting, the authorities addressed the cross-border issues related to the implementation of new legislation and rules to govern the OTC derivatives markets in their respective jurisdictions.

At the conclusion of the meeting, the authorities agreed to continue bilateral regulatory dialogues and to meet as a group again in early 2012."

Joint Statement on Regulation of OTC Derivatives Markets

SEC Charges Wachovia with Fraudulent Bid Rigging in Municipal Bond Proceeds

The SEC charged Wachovia Bank N.A. with fraudulently engaging in secret arrangements with bidding agents to improperly win business from municipalities and guarantee itself profits in the reinvestment of municipal bond proceeds. Over a period of eight years, the SEC alleges that Wachovia fraudulently rigged at least 58 municipal bond reinvestment transactions, generating millions of dollars in illicit gains.

“Wachovia won bids by playing an elaborate game of ‘you scratch my back and I’ll scratch yours,’ rather than engaging in legitimate competition to win municipalities’ business,” said Robert Khuzami, Director of the SEC’s Division of Enforcement.

Wachovia agreed to settle the charges by paying $46 million to the SEC, which will be returned to affected municipalities or conduit borrowers. The settlements arise out of long-standing parallel investigations into widespread corruption in the municipal securities reinvestment industry.

SEC Charges Wachovia with Fraudulent Bid Rigging in Municipal Bond Proceeds

SEC Halts Prime Bank Scheme by Washington DC Law Firm and Pennsylvania Company

The SEC announced that it has filed charges and obtained an emergency court order to halt a prime bank scheme in which the perpetrators stole investor funds to purchase luxury cars, take a trip to the Bahamas, and pay the bills of a Washington D.C. law firm. The two individuals being charged are a Pennsylvania resident and a Washington D.C. attorney who defrauded at least 13 investors out of more than $2 million since August 2010.

The SEC alleges that they offered investors risk-free returns of up to 20 times the original investment within as few as 45 days through the purported “lease” and “trading” of foreign bank instruments in highly complex transactions involving unidentified parties and secretive “trading platforms.” Yet all the bank instruments and trading programs were entirely fictitious. Investors in schemes like this are often told that details are too difficult for non-experts to understand, and that secrecy is required for success. In this case, they used vague and complex terms to confuse investors, and claimed that confidentiality concerns prevented them from providing more details regarding the status of the investment. The D.C. attorney and her law firm acted as counsel for the Pennsylvania resident.

SEC Halts Prime Bank Scheme by Washington DC Law Firm and Pennsylvania Company

SEC Announces National Seminar for Compliance Officers and Senior Personnel at Investment Management Firms

The SEC announced the opening of registration for its national seminar to help chief compliance officers and other senior personnel at investment management firms enhance their compliance programs for the protection of investors. The event will be held on Jan. 31, 2012, at the SEC’s Washington D.C. headquarters, and will include panel discussions to analyze compliance and other significant issues being faced by investment advisers and registered investment companies.

SEC Announces National Seminar for Compliance Officers and Senior Personnel at Investment Management Firms

SEC Charges Multiple Hedge Fund Managers with Fraud in Inquiry Targeting Suspicious Investment Returns

As part of the Aberrational Performance Inquiry, an initiative to combat hedge fund fraud by identifying abnormal investment performance, the SEC took enforcement action against three separate advisory firms and six individuals for various misconduct. The SEC alleges that they engaged in a wide variety of illegal practices in the management of hedge funds or private pooled investment vehicles, including fraudulent valuation of portfolio holdings, misuse of fund assets, and misrepresentations to investors about critical attributes such as performance, assets, liquidity, investment strategy, valuation procedures, and conflicts of interest.

Under the initiative, the SEC Enforcement Division’s Asset Management Unit uses proprietary risk analytics to evaluate hedge fund returns and red flags performance that appears inconsistent with a fund's investment strategy.

“We’re using risk analytics and unconventional methods to help achieve the holy grail of securities law enforcement — earlier detection and prevention,” said Robert Khuzami, Director of the SEC’s Division of Enforcement. “This approach, especially in the absence of a tip or complaint, minimizes both the number of victims and the amount of loss while increasing the chance of recovering funds and charging the perpetrators.”

SEC Charges Multiple Hedge Fund Managers with Fraud in Inquiry Targeting Suspicious Investment Returns

SEC, US Attorney and FBI Announce 13 Charged in Connection with Securities Kickback Schemes

The SEC, U.S. Attorney for the District of Massachusetts and FBI today announced parallel cases filed in federal court against several corporate officers, lawyers and a stock promoter. The cases allege that the 13 defendants used kickbacks and other schemes to trigger investments in various thinly-traded stocks. The kickbacks, concealed by sham consulting agreements, were given to an investment fund representation for buying stock in specific companies. This representation was actually an undercover FBI agent.

These charges follow a year-long investigation focusing on preventing fraud in the micro-cap stock markets, which have become an increasingly common area for fraud and abuse. Microcap companies are small publicly traded companies whose stock often trades at pennies per share. As a result, many microcap companies do not file financial reports with the SEC, which makes it more difficult for investors to find information. In October 2010 and June 2011 similar cases were filed.

“The public has a right to invest in an honest and fair market. Companies that agree to pay illegal kickbacks harm investors and undermine fair competition in the markets,” said United States Attorney Carmen Ortiz. “Hard working Americans who invest their savings should not be subjected to backroom deals like those alleged today.”

SEC, US Attorney and FBI Announced 13 Charged in Connection with Securities Kickback Schemes

Woman Sues Bank of America Over Its Foreclosure Procedures

An Austin woman filed suit Thursday against Bank of America Corp., alleging the company fraudulently sought to foreclose on her home. The suit claims that the bank wrongly invalidated a loan modification agreement because it wasn't signed by her husband even though he died in 2007, more than three years before the agreement was made. Filed in state District Court in Travis County, the lawsuit by Maria Gonzales comes on the same day a Massachusetts lawsuit accused five of the nation's largest banks — including Bank of America — of deceptive foreclosure practices. 

http://www.statesman.com/business/austin-woman-sues-bank-of-america-over-foreclosure-2007435.html

FINRA Fines Wells Investment Securities $300,000 for Misleading Marketing Tools

FINRA announced that it has fined Wells Investment Securities, Inc. $300,000 for using misleading marketing materials in the sale of Wells Timberland REIT, Inc., a non-traded Real Estate Investment Trust (REIT). As the wholesaler, Wells Investment Securities had the responsibility to review, approve and distribute the marketing materials. From May 2007 to September 2009 the 116 materials that were distributed contained misleading, unwarranted or exaggerated statements. The advertisements at issue did not make it clear to potential investors who might be seeking such favorable tax treatment, that the investment at issue was not yet a REIT. Therefore, it would not be able to offer the desired tax benefits at the time the ads were being used. The investigation has also found that Wells supervisory procedures failed to ensure the security of customer and proprietary information that was stored on laptops.

Brad Bennett, FINRA Executive Vice President and Chief of Enforcement, said, "By approving and distributing marketing materials with ambiguous and equivocal statements, Wells misled investors into thinking Wells Timberland was a REIT at a time when it was not a REIT. Firms need to be mindful that investors rely on marketing materials to disclose truthful, accurate and up-to-date information to help inform their investment decisions."

FINRA Fines Wells Investment Securitites $300,000 for Use of Misleading Marketing Materials for REIT Offering

SEC Penalizes Investment Advisers for Compliance Failures

The SEC charged three investment advisers for failing to put in place compliance procedures designed to prevent securities law violations. This results from an initiative to actively prevent harm to investors by working with agency examiners to ensure that compliance programs are in place at firms. In two of the cases, the firms had been previously warned about compliance deficiencies.

The SEC Press Release states that "Under Rule 206(4)-7 of the Investment Advisers Act, which is known as the “Compliance Rule,” registered investment advisers are required to adopt and implement written policies and procedures that are reasonably designed to prevent, detect, and correct securities law violations. The Compliance Rule also requires annual review of the policies and procedures for their adequacy and the effectiveness of their implementation, and designation of a chief compliance officer to be responsible for administering the policies and procedures. " Specific details on the three cases can be found at the link below.


SEC Penalizes Investment Avisers for Compliance Failures