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Policies and Procedures Failure-to-File

Orrick, Herrington & Sutcliffe LLP

FINRA fines broker-dealer $500K for failure to file suspicious activity reports

On August 22, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) from a broker-dealer member firm regarding its alleged failure to establish and implement policies and procedures designed to detect suspicious...more

Foley & Lardner LLP

Recent MCDC Settlements Provide Guidance Concerning Scope of Materiality in Continuing Disclosure Obligations

Foley & Lardner LLP on

In responding to the Securities and Exchange Commission’s recent Municipalities Continuing Disclosure Cooperation (MCDC) initiative, the unanswered question for many municipalities and broker-dealers was determining whether...more

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