Journal of Investment Compliance: Volume 15 Issue 3

High-frequency traders: a review of the challenges in registering them as dealers

Mark Fitterman, Ignacio Sandoval

– To describe some of the challenges that the Securities and Exchange Commission (SEC) will face in requiring that high-frequency traders register as dealers.

Recent regulatory developments provide some clarifications regarding the market access rule for broker-dealers

Bruce H. Newman, Elizabeth Mitchell, Stephanie R. Nicolas, Andre Owens, Ashley E. Bashur

To provide an overview of recent developments relating to the Securities and Exchange Commission (SEC)’s Market Access Rule, Rule 15c3-5 promulgated under the Securities Exchange…

Marketing funds in Europe: a practical look at the marketing regime under the Alternative Investment Fund Managers Directive 2011/61/EU and other regulatory requirements

Jacob Ghanty, Justin Cornelius, Matthew Baker, Chris Ormond

To provide a practical look at the Alternative Investment Fund Managers Directive 2011/61/EU (AIFMD) and other regulatory requirements as they pertain to marketing funds in…

Tweeting corporate disclosures: SEC staff issues guidance permitting hyperlinks to cautionary statements and legends in social media communications

Richard J. Parrino, Kevin K. Greenslade

To review guidance issued in April 2014 by the staff of the USA Securities and Exchange Commission (SEC) that clarifies how participants in regulated securities offerings…

SEC settles with adviser over failure to consider account aggregation requests in applying fee breakpoint discounts

Jackson Galloway, Nicole Griffin

To review SEC enforcement action taken against an adviser over: failure to grant advisory fee breakpoint discounts based on the aggregation of related accounts requested by…

SEC announces first investment adviser ‘pay-to-play’ enforcement action

M. Norman Goldberger, John C. Grugan, Christine O’Neil, Tesia N. Stanley

To explain the first enforcement action the USA Securities and Exchange Commission (SEC) has brought under “pay to play” rules for investment advisers since those rules were…

SEC administrative law judge bars investment manager for misrepresenting GIPS compliance

Michael S. Caccese, Douglas Y. Charton, Pamela A. Grossetti

To explain an administrative law judge (ALJ) decision, along with a censure, fine, and industry disbarment, against an investment adviser for misleading advertising and false…

Commodity Futures Trading Commission provides new streamlined process for commodity pool operators to request no-action relief for delegating certain activities to registered CPOs

Walid Khuri, Robert M. McLauglin, David S. Mitchell, David W. Selden

To provide an overview of a new, streamlined process from the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) by which…

New MSRB fair-pricing rule effective July 7, 2014

Scott R. Anderson

– To summarize revised MSRB Rule G-30, which governs municipal bond dealer fair-pricing obligations.

Editor’s letter

Henry Davis