Purpose – The purpose of this paper is to review recent regulatory enforcement actions sanctioning firms for failure to safeguard material, non‐public information (MNPI). Design/methodology/approach – The paper reviews recent enforcement actions and examines the implications for other firms who may face similar scrutiny from regulators for deficient policies and procedures and controls relating to their information barriers; makes recommendations on how firms can avoid similar mistakes through improving internal controls. Findings – Firms need to be especially vigilant in protecting their MNPI by reviewing their policies and procedures to reflect the firm's current business model. Firms must also take steps to ensure that supervisors fully understand their role in implementing and enforcing the firm's policies and procedures. Practical implications – Firms should conduct a comprehensive review of their business to understand which units come into possession of MNPI and how related entities interact with one another and could potentially share MNPI. Once these tasks are complete, firms will be better positioned to review their policies and procedures relating to safeguarding MNPI. Failure to do so may result in substantial monetary fines and being forced to retain an independent consultant. Originality/value – The paper serves as a reminder to firms about the implications of failing to have adequate controls to safeguard MNPI from both a monetary and public relations standpoint.
Journal of Investment Compliance – Emerald Publishing
Published: Nov 29, 2011
Keywords: Securities regulation; Broker‐dealers; Investment advisers; Investments; Advisory services; Information disclosure; Regulation; United States of America
It’s your single place to instantly
discover and read the research
that matters to you.
Enjoy affordable access to
over 18 million articles from more than
15,000 peer-reviewed journals.
All for just $49/month
Query the DeepDyve database, plus search all of PubMed and Google Scholar seamlessly
Save any article or search result from DeepDyve, PubMed, and Google Scholar... all in one place.
Get unlimited, online access to over 18 million full-text articles from more than 15,000 scientific journals.
Read from thousands of the leading scholarly journals from SpringerNature, Wiley-Blackwell, Oxford University Press and more.
All the latest content is available, no embargo periods.
“Hi guys, I cannot tell you how much I love this resource. Incredible. I really believe you've hit the nail on the head with this site in regards to solving the research-purchase issue.”Daniel C.
“Whoa! It’s like Spotify but for academic articles.”@Phil_Robichaud
“I must say, @deepdyve is a fabulous solution to the independent researcher's problem of #access to #information.”@deepthiw
“My last article couldn't be possible without the platform @deepdyve that makes journal papers cheaper.”@JoseServera