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Category Archives: Insider Trading

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What To Expect In 2014 From The SEC’s Enforcement Division

Posted in Broker-Dealer Regulation, Hedge and Private Equity Funds, Insider Trading, Internal Investigations, Investment Adviser Regulation, SEC Compliance, SEC Enforcement, SEC Organization, SEC Structure, Whistleblowers

Now that 2014 is here, it is a good idea to understand what the Enforcement Division might focus on this year.  In a recent article that appeared in the BNA, David Marder, a partner with Robins, Kaplan, Miller & Ciresi identified fifteen things to expect in the coming year.  The fifteen things he noted to… Continue Reading

SEC Exam and Enforcement Converging Into One?

Posted in Broker-Dealer Regulation, Insider Trading

There is concern over the increasing collaboration between the Securities and Exchange Commission’s Enforcement Division and Office of Compliance Inspections and Examinations. The SEC views this collaboration as efficient while others view it in the extreme.  SEC officials have acknowledged the increasingly close working relationship between OCIE and the Enforcement Division. OCIE assists the SEC’s… Continue Reading

Preventing Misuse of Material Information by BDs

Posted in Insider Trading

The SEC’s Office of Compliance Inspections and Examinations has issued a report on broker-dealers’ handling of confidential information.  The SEC’s examiners looked at broker-dealers’ compliance with the requirements governing the misuse of material nonpublic information, and evaluated new business practices, technologies and controls relating to compliance. Broker-dealers have access to nonpublic information, and owe a… Continue Reading


Posted in Insider Trading, Securities Fraud, STOCK Act

A court has held that the privacy rights of thousands of high-level federal employees could be violated if a provision of the Stop Trading on Congressional Knowledge Act (“STOCK Act”) were enforced.  The STOCK Act requires online disclosure of employees’ financial information, and it would have become effective but for the United States District Court… Continue Reading


Posted in Insider Trading, SEA Rule 10b5-1 Plans, SEC Enforcement

The SEC has announced it is monitoring if there is abuse of so-called Securities Exchange Act of 1934 Rule 10b5-1 stock trading plans.  The SEC stated that it will monitor the situation, and, if it finds that there is abuse, the SEC will consider action, especially if it is a high level executive.  The SEC… Continue Reading