Bridging the Week by Gary DeWaal: September 21 to 25 and 28, 2015 (Aggregation, Cybersecurity, Wash Sales, Fund Redemptions, IB Records, CTA Registration)
Many old themes re-emerged in the financial services industry last week. The Commodity Futures Trading Commission revised its proposed new rules dealing with the aggregation of accounts in connection with position limits, while the Securities and Exchange Commission brought an enforcement action against an investment adviser for failing to have a cybersecurity program to protect customer records and information. In addition, the SEC proposed rules to help ensure open-ended funds have enough liquidity to meet redemption demands during a crisis, while the CFTC brought two actions alleging impermissible wash sales – one against a swap execution facility. As a result, the following matters are covered in this week’s edition of Bridging the Week:
- CFTC Revises Aggregation Proposal Related to Position Limits;
- SEC Sanctions Investment Adviser for Not Implementing Policies and Procedures in Advance of Cyber-Attack (includes Compliance Weeds);
- Former Investment Bank Financial Adviser Pleads Guilty to Illegally Accessing Confidential Client Information (includes Compliance Weeds);
- Tera Exchange Consents to Cease and Desist Order by CFTC for Encouraging Wash Sale, No Fine Assessed:
- SEC Seeks to Enhance Liquidity Management by Mutual Funds and ETFs;
- Déjà Vu All Over Again – CFTC Settles Complaint With Cargill de Mexico for Wash Sales Following Similar CME Group Settlement (includes Compliance Weeds and My View);
- Introducing Broker and COO Agree to Pay US $500,000 to Resolve CFTC Charges of Recordkeeping Violations and Supervision Breakdown;
- CTA Fined US $280,000 by CFTC for Not Disclosing Principal and Changes to Algorithmic Trading System; and more.
Click here to access the video and article versions of this week’s version of Bridging the Week.
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For further information, contact:
Gary DeWaal
Katten Muchin Rosenman LLP
575 Madison Avenue
New York, New York
(212) 940-6558
gary.dewaal@kattenlaw.com
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