Month: August 2018

When firms make representations regarding the policies and procedures that govern their operations it is critically important that they be reviewed and updated as required. Perhaps more importantly, the firm should have internal compliance procedures which ensure that it is …

MLPFS Pays Over $8 Million to Settle SEC Conflict Based Fraud Charge Read More »

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The Commission’s enforcement program has increasingly relied on statistical analysis. One of its initiatives, the Aberrational Performance Inquiry or API, focuses on whether performance and other metrics fell within certain limits. In some instances it has been successful; some not. …

The SEC, Enforcement and Statistics Read More »

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