On September 27, 2012 the SEC issued a staff report intended to help broker-dealers safeguard confidential information from misuse like inside trading. Specifically, this report should help broker-dealers assess the effectiveness of their controls over sensitive information. To assess this information, the report lists types of conflicts of interest that may arise between a broker-dealer’s obligations to clients. The report also describes various methods that broker-dealers use to identify and effectively manage such conflicts.
The types of issues identified in the report may be helpful to firms as they review their conflict of interest risk management programs. In particular, in any review of information barriers control programs, broker-dealers should be alert to changes in business practices and available compliance tools.
Eccleston Law Offices counsels, represents and defends financial advisers nationwide in regulatory, compliance, disciplinary and employment matters in arbitration and litigation, and before regulatory bodies such as the SEC, FINRA and state securities regulators. We frequently defend forgivable loan collection actions, prosecute Form U-5 defamation actions, counsel advisers as to how to transition successfully from firm to firm and negotiate the best possible agreements with their new firm, and provide succession planning, buy-sell agreements and other exit strategies and strategic consulting, practice transitions, mergers, acquisitions and divestitures.
