Andy Melnick and Brian Walsh author Schwab’s Compliance Review and Personal Trading - In its February 2017 Risk Alert, the Securities and Exchange Commission (SEC) identified personal trading by investment advisor “access persons” as an area in which examination staff frequently find compliance failures. This notification to firms underscores the importance that the SEC ascribes to personal trading compliance. This white paper details the rule covering personal trading, provides practical tips for compliance, and discusses relevant enforcement cases that have resulted from noncompliance.
Each year Murphy & McGonigle collects school supplies to give to local charities in our communities so that more children have the materials they need to start the school year off right.
This Briefing will provide a roadmap of common plaintiffs' arguments and defendants' rebuttal arguments in actions filed by or on behalf of elder investors. Elizabeth M. Del Cid and Sharon A. O’Shaughnessy of Murphy & McGonigle will discuss recent rules and notices published by the regulators on senior investors, the standards of proof for financial elder abuse that arise in these cases in major jurisdictions (NY, CA, FL, VA, and NC), and the potential civil and criminal penalties that may be imposed.
Securities industry participants should be well-prepared for the introduction of a shortened settlement period for most broker-dealer securities transactions. Effective on September 5, 2017, amended Exchange Act Rule 15c6-1 prohibits a broker-dealer from effecting or entering into a contract for the purchase or sale of a security that provides for payment of funds and delivery of securities later than T+2, unless otherwise expressly agreed to by the parties at the time of the transaction. As the SEC has explained: “The amended rule [applies] the T+2 settlement cycle to the same securities transactions currently covered by the T+3 settlement cycle. These include transactions for stocks, bonds, municipal securities, exchange-traded funds, certain mutual funds, and limited partnerships that trade on an exchange.”
What is a Regulation SHO bona-fide market maker? As discussed below, this actually is a trick question, because Regulation SHO does not contemplate that a broker-dealer would have the status of a “bona-fide market maker,” but focuses on whether a market maker is engaged in “bona-fide market making activities.”