Broken Windows: SEC Makes Good on Promise to Enforce “Minor” Violations
Although SEC Chair Mary Jo White first shared the SEC’s plan to apply the theory of “broken windows” to financial services compliance in 2013, recent news of several firms being charged with relatively smaller violations is evidence that the SEC is serious about nipping small violations in the bud in an effort to curtail larger violations.
Yes, the large violations are still in the news, but smaller violations are also taking center stage:
- SEC Press Release, September 10, 2014: SEC Announces Charges Against Corporate Insiders for Violating Laws Requiring Prompt Reporting of Transactions and Holdings
- SEC Press Release, September 16, 2014: SEC Sanctions 19 Firms and Individual Trader for Short Selling Violations in Advance of Stock Offerings
Instructors will examine recent headlines and explore reasons why these violations demonstrate a “zero tolerance” approach from SEC enforcement, and how this approach is playing out in the examination and enforcement process. The instructors will discuss ways to bolster the firm’s compliance program to meet SEC expectations for identifying large and small violations.
After attending this course, you will be able to:
- Decipher how technology has increased the SEC’s ability to detect smaller degrees of negligent behavior
- Determine why irregularities that might have been overlooked in your firm’s previous examinations could become big problems in the future
- Assess how the increased cooperation between the SEC examination and enforcement programs could affect your firm
- Create an action-oriented plan to help your firm avoid an SEC investigation and a possible enforcement action
For Whom: Designed to increase the professional competence of financial securities professionals with legal, compliance, technology and management responsibilities
Suggested Skill Level: Intermediate
Instructional Method: Group Internet-Based
Pre-requisites for participation: No advance preparation or prerequisites are required. However, attendees can benefit by reviewing the SEC Examination and Enforcement Programs at www.sec.gov.
Advance Preparation: None
NRS Continuing Education Guide
Maximum recommended CPE Credit: 2 in the Regulatory Ethics field of study
Maximum recommended IACCP® CE Credit: 2
Maximum recommended CA MCLE Credit: 2
Maximum recommended CFP® Credit: pending