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Steven Lofchie Commentary by Steven Lofchie

An investment advisory firm, its two owners and a former chief compliance officer ("CCO") have agreed to settle charges that the firm violated Advisers Act Rule 206(4)-2 (the "custody rule") by failing to produce audited financial statements after being reprimanded for a violation several years before, and for failing to take remedial measures. The firm and its co-founders agreed to pay a $1 million penalty and to a year's suspension from raising money from new or existing investors. Its CCO agreed to pay a $60,000 penalty and to a year's suspension from acting as a CCO or appearing or

Steven Lofchie Commentary by Steven Lofchie

In the first installment of a four-part series covering its new research rules, FINRA reviewed consolidated Rule 2241 provisions governing conflicts of interest in equity research reports. In the podcast, FINRA noted that the new rule: broadens firms' obligations to identify and manage research-related conflicts of interest; imposes an overarching requirement on firms to establish written policies and procedures to identify and effectively manage conflicts of interest related to the preparation, content and distribution of research reports and public appearances by research analysts; strikes

Steven Lofchie Commentary by Steven Lofchie

The SEC held its 34th annual Government-Business Forum on Small Business Capital Formation. Regulators at the Forum discussed initiatives to facilitate capital formation for small and emerging companies. Chair White outlined recent SEC efforts supporting capital formation for small and emerging companies including: finalizing rules in connection with the JOBS Act that permit startups and small businesses to raise capital by offering and selling securities through crowdfunding; finalizing rules on Regulation A (popularly known as "Regulation A+"), which allows for lightly regulated offerings of

Steven Lofchie Commentary by Steven Lofchie

In its 29th semi-annual "European Repo Market Survey," the International Capital Market Association ("ICMA") reported that the trend in European repurchase agreement ("repo") activities is "still essentially sideways." The findings of the survey included this fact and observation: Concentration Analysis. There was an increase in the concentration of business in the top 10 survey respondents, "reflecting the very significant increases in the repo books of a few of the very largest banks." In light of these results, the survey stated, "it is a valid question to ask why these banks have

Federal Reserve Bank of New York President and CEO William C. Dudley and FDIC Chair Martin J. Gruenberg reviewed the progress made to date in improving bank regulation. At the Clearinghouse Annual Conference, Mr. Dudley outlined work that still needs to be done within both the official sector and the largest banking firms to effect an operational resolution for global systemically important banking organizations ("GSIBs"). Mr. Dudley stated that the policy approach to "too big to fail" reduces but does not completely eliminate the possibility of a large financial institution's failure and that