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BD and IA Conflicts of Interest: SEC Staff Says Don't Set It (Them) and Forget It (Them)

Our recent client alert discusses a recent SEC staff bulletin covering the standards of conduct for broker-dealer and investment adviser conflicts of interest. The staff bulletin includes 13 Q&As categorized into five different flavors relating to identifying, eliminating, mitigating, and disclosing conflicts of interest, as well as related to product…

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CFTC Commissioner Romero Calls on Agency to Bring the "HEAT" in Enforcement Actions

Our recent client alert discusses the CFTC’s longstanding practice of settling enforcement cases without seeking admissions of wrongdoing (so-called “no-admit/no-deny” settlements). CFTC Commissioner Romero suggests application of a “HEAT” test (Heightened Enforcement Accountability and Transparency), which would encourage CFTC staff to push for admissions of wrongdoing in actions with one or more bad…

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