5 responses to “April 28 Webcast — Inside the SEC Enforcement Division: Current and Former SEC and DOJ Prosecutors Discuss Important Changes Ahead”

  1. […] SEC’s plans for allocating and building its resources in further in the April 28 webcast, “Inside the SEC Enforcement Division: Current and Former SEC and DOJ Prosecutors Discuss Important Ch….”  For for more information and to register for this free webcast, please visit this […]

  2. […] APRIL 28: “Inside the SEC Enforcement Division: Current and Former SEC and DOJ Prosecutors Discuss Important… […]

  3. Do you believe that Reg AB and its transparency was one of the leading factors that exposed the problems with Mortgage Industry and specific lenders? To date no one has answered this questions in any of the Banking or SEC forums around the US or World. I will not be able to attend the session because I am giving a speech on the Financial Crisis to about 500 CPAs and CFEs on the same day. Could you let me know the answer?

    Thanks for your help,

    Tom Borgers, CFE

  4. It has not been several years since the SEC adopted Rule 206(4)-7. However, most major asset management firms have a culture that compromises the independence of compliance. This is accomplished in a very subliminal way that SEC examiners would not have the experience to detect upon a routine inspection.

    I have two questions for the SEC: i) what additional steps is the SEC going to take to insure that compliance has the independence to discharge its duties in accordance with the spirit of the law? ii) Why hasn’t the SEC amended Rules 206(4)-7 and 38a-1 to require registrants to adopt policies and procedures to insure compliance independence with minimum criteria of: a) registrants demonstrating that compliance is not beholden to business, b) compliance report directly to the independent board, c) compliance has the power to terminate any employee for serious compliance violations or for not cooperating, c) can write part of the performance evaluations of business heads that has at least a 25% weight to the overall score, with a commensurate impact to bonus and salary increases, d) can make recommendations in a report to the independent Board regarding whether the CCO, CFO, COO, CEO is projecting the proper tone at the top or when they are compromised by dollar stained glasses, with the requirement to file this report with the SEC?

    If Compliance is disconnected from the business, there would be less politics adversely impacting the difficult decisions compliance needs to make on a day-to-day basis.

  5. Could you please describe the changes being considered for the SEC whistleblower program? I’ve read the SEC is considering a reward provision like the IRS Tax Whistleblower Reward Program. Are you working with Congress to implement changes to the SEC whistleblower policy?

    Thank you.