As a compliance officer, how far do you need to go in dealing with a problem employee? The Urban case was trying to address this question, but got twisted up in procedural machinations. In dropping the case, the two SEC commissioners didn’t explain when a compliance officer or in-house counsel at a broker-dealer or investment adviser becomes a supervisor liable for an employee’s actions….
… The final decision by the SEC leaves it murky as to whether that position by the Enforcement Division is the position of the Commissioners. If you can’t get a compliance problem fixed what should you do?
‘Enforcement 40’ for 2020
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