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November 16, 2008

SEC Sunday November 16, 2008

This is the latest edition of the SEC Sundays. Please come back every Sunday for the week’s update on all the Regulatory alerts. 

11/06/08: Compliance Tool

Financial Intermediary Controls and Compliance Assessment

The ICI has developed a new tool to help funds review the internal controls of broker-dealers, fund supermarkets, and other financial intermediaries that hold clients' mutual fund investments. This new framework promises funds a higher level of assurance that investor transactions are properly executed and that shareholder accounts are properly maintained.

Financial Intermediary Controls and Compliance Assessment Sample

ICI Press Release

11/06/08: Speech by Sarah Wilson, Director and Insurance Sector Leader, FSA, at

Westminster and City conference on Rethinking Life Insurance: Capital, Risk and Strategy

Capital, Risk and Strategy: The Regulator's View of Life Insurance

11/06/08: Speech by Jamie Symington, Head of Wholesale Department, FSA, at City and Financial Market Abuse Conference

The FSA and Enforcing the Market Abuse Regime

11/6/08: Division of Corporation Finance, No-Action, Interpretive and Exemptive Letters

BlackRock Advisers LLC, - Securities Exchange Act of 1934, Section 16(a), (November 4, 2008)

11/6/08: Division of Investment Management, Staff No-Action and Interpretive Letters

Comdisco, Inc., (Creation of “Tracking Stock”), October 25, 2000

Willkie Farr & Gallagher, (Issuer May Treat Money Market Fund Shares as "Cash Items), October 23, 2000

Mackenzie Investment Management et al., (Personal Trading Reporting Requirements of Rule 17j-l), August 8, 2000

Jennison Associates LLC, (Records Management), July 6, 2000

Massachusetts Mutual Life, (Aggregates Orders for the Purchase and Sale of Private Placement Securities), June 7, 2000

Brown & Wood, (Business Trust Not Needed to Register Under the IAA), February 24, 2000

General Motors Investment Management, (Collective Investment Trust with Respect to Unrelated Employers Comprised of Separate Single Stock Funds that are Managed by a Bank as Described Above is "Maintained by a Bank" for the Purposes of ICA), February 20, 2000

R.O.C. Taiwan Fund, (Adviser Acts as Investment Adviser of the Trust Under the Investment Contract After the Implementation of a Permanent Reduction in the Amount of the Compensation Paid Under the Investment Contract to the Adviser, the Custodian, or Both of Them, Without Seeking and Obtaining Shareholder Approval) February 11, 2000

Pengrowth Energy Trust, (Pengrowth Energy Trust Treating its Subsidiary, Pengrowth Corporation, as a Majority Owned Subsidiary for Purposes of Section 3(A)(I)(C) Under the ICA and, Therefore, Does not Need to Register as an Investment Company.) January 27, 2000

11/06/08: Division of Trading and Markets, Exemptive Orders and Exemptive, Interpretive, and No-Action Letters

Lloyds TSB Group plc, (Exemption from Rule 102 of Regulation M Under the Securities Exchange Act of 1934 in Connection With the Distribution of LTSB Ordinary Shares), October 21, 2008

11/06/08: Administrative Proceeding

In the Matter of Karnig H. Durgarian, Jr (Fraudulent Scheme to Cover Up Losses)

11/06/08: Administrative Proceeding

In the Matter of Ronald B. Hogan (Fraudulent Scheme to Cover Up Losses)

11/06/08: Administrative Proceeding

SEC v. Michael E. Kelly, et al. (Massive Fraud on U.S. Investors That Involved the Offer and Sale of Securities in the Form of Universal Lease Investments)

11/06/08: Press Release

SEC Approves a National Market System Plan for the Selection and Reservation of Securities Symbols

11/06/08, FRB: Final Rule

Reg A: Extensions of Credit by Federal Reserve Banks

The Board of Governors of the Federal Reserve System (Board) has adopted final amendments to its Regulation A to reflect the Board's approval of a decrease in the primary credit rate at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically decreased by formula as a result of the Board's primary credit rate action. The amendments to part 201 (Regulation A) are effective November 6, 2008. The rate changes for primary and secondary credit were effective on the dates specified in 12 CFR 201.51, as amended.

11/06/08, IRS: Final Regulations and Removal of Temporary Regulations

Information Reporting on Employer-Owned Life Insurance Contracts

This document contains final regulations concerning information reporting on employer-owned life insurance contracts under section 6039I of the Internal Revenue Code (Code). This final regulation is necessary to provide taxpayers with guidance as to how the requirements of section 6039I should be applied. These regulations generally apply to taxpayers that are engaged in a trade or business and that are directly or indirectly a beneficiary of a life insurance contract covering the life of an insured who is an employee of the trade or business on the date the contract is issued. These regulations are effective on November 6, 2008. These regulations are applicable for tax years ending after November 6, 2008.

11/06/08: Speech by Governor Kevin Warsh

The Promise and Peril of the New Financial Architecture

11/07/08, FinCEN: Proposed Rule

Transfer and Reorganization of Bank Secrecy Act Regulations

FinCEN proposes to move Bank Secrecy Act (BSA) regulations to a new chapter in the Code of Federal Regulations (CFR). The new chapter would contain the BSA regulations, which would generally be reorganized by financial industry. Moving the BSA regulations to a new chapter and organizing the chapter by financial industry would create a user-friendly way to find regulations applicable to a particular financial industry. This new organization within the new chapter also allows for the renumbering of the BSA regulations in a manner that would make it easier to find regulatory requirements than under the numbering system currently used in the existing regulations. FinCEN also proposes to make minor technical changes to the BSA regulations such as updating mailing addresses and points of contact. Written comments must be submitted on or before March 9, 2009.

11/07/08: FIL-127-2008

Guidance on Payment Processor Relationships

11/07/08: Press Release

FDIC Extends Comment Period for Portions of Proposed Rulemaking on Risk-Based Assessments

FIL-126-2008

11/07/08: Division of Corporation Finance, Staff Legal Bulletin No. 14D (CF)

Shareholder Proposals

11/07/08: Staff No-Action, Interpretive Exemptive Letters

Shareholder Proposals – Individual No Action Letters

Deere & Company (October 22, 2008)

AT&T Inc. (October 7, 2008)

UGI Corporation (October 10, 2008)

Applied Materials, Inc. (November 5, 2008)

Becton Dickinson & Co (October 8, 2008)

Whole Foods Market, Inc. (October 31, 2008)

Apple Inc. (October 15, 2008)

11/07/08: Administrative Hearing

In the Matter of Carmine J. Bua

The Commission’s complaint alleged that Bua drafted numerous legal documents in furtherance of a fraudulent scheme to illegally issue free-trading shares of Global Development & Environmental Resources, Inc. (“Global”), including an attorney opinion letter that directed Global’s transfer agent to improperly issue nearly 2.7 million shares to three foreign entities that sold their shares to the investing public during a fraudulent promotional campaign.

11/07/08: Speech by Chairman Christopher Cox at SEC International Enforcement Institute, Washington, D.C.

The Importance of International Enforcement Cooperation in Today's Markets

11/07/08: Speech by Commissioner Luis A. Aguilar before the 14th Annual Securities Litigation and Regulatory Practice Seminar, Atlanta, Georgia

Recent Adventures at SEC

11/07/08: Commission Orders

Review of Disciplinary Actions

Vincent M. Uberti (November 7, 2008)

James W. Browne and Kevin Calandro (November 7, 2008)

Nasdaq Stock Market, LLC (November 7, 2008)

11/07/08: Recent Actions

Update - TSRA Program Application Guidelines

The Office of Foreign Assets Control (OFAC) has updated its guidelines for submitting applications to OFAC pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) for a license to export agricultural commodities, medicine and medical devices to Iran and Sudan.

11/07/08: Regulatory Notice 08-67

FINRA Announces Electronic Filing Process For Qualification Examination Waiver Requests and Series 16 Experience Acceptability Requests

11/07/08: Announcements & Speeches

Summary of IASC Foundation Trustees’ Meeting – October 2008

The Trustees of the IASC Foundation today announced the conclusions of their meeting in Beijing, China, on October 9 and 10, 2008

11/10/08: Division of Corporation Finance — Staff No-Action, Interpretive Exemptive Letters

Consonus Technologies, Inc. (November 10, 2008)

Re: Rule 12h-3 - Suspension of duty to file reports under Section 15(d))

United Online, Inc. (November 7, 2008)

Re: Rule 12h-3 - Suspension of duty to file reports under Section 15(d))

11/10/08: Board Order

Approval of Proposal by American Express Company and American Express Travel Related Services Company to Become Bank Holding Companies

11/12/08: Joint Agency Press Release

Interagency Statement on Meeting the Needs of Creditworthy Borrowers

FRB:

FDIC:

FIL-128-2008

OCC:

OTS:

11/12/08: Speech by Vice Chairman Donald L. Kohn at the Official Celebration of the 10th Anniversary of the Banque Centrale du Luxembourg, Luxembourg, Luxembourg

Productivity and Innovation in Financial Services

11/12/08: Federal Reserve Bank of New York

New York Fed Endorses TMPG Best Practice Initiatives

11/12/08: FinCEN Publication Link

SAR Activity Review – By the Numbers (Issue 11 – November 2008)

11/12/08: Litigation Release

Blue Coat Systems and Former CFO Settle Charges of Stock Option Backdating

Related Litigation Release

Related SEC Complaint

Related Article from Investment News Daily Alert

11/12/08: Speech by SEC Chairman Christopher Cox at PLI 40th Annual Securities Regulation Institute, New York, New York

'Building on Strengths in Designing the New Regulatory Structure'

11/12/08: Publication

SAR Activity Review - By the Numbers – Issue 11

Link to Previous Issues of SAR Activity Review

11/12/08: Recent Actions

Anti-Terrorism Designations

0n November 12, 2008, OFAC designated 1 entity as a terrorism organization and added and its aliases to its SDN List

OFAC Terrorism Sanctions Brochure updated as of November 12, 2008

SDN List updated as of November 12, 2008 (in Alphabetical Order)

SDN List Updated as of November 12, 2008 (Additions since January 1, 2008)

11/12/08: Letter

IOSCO Open Letter to G-20 Summit

Related Media Release

11/12/08: Monthly Disciplinary Actions

NYSE Regulation Announces November Disciplinary Actions

Charles Winitch

Violated NYSE Rule 476 (a)(6) by effecting unauthorized trades in three customer accounts, effecting trades in eight customer accounts that were unsuitable given customer's age, circumstances, investment objectives and investment experience, and by making material misstatement to NYSE; violated NYSE Rule 408(a) by exercising discretionary authority over customer's accounts without written authorization. Censure and five-year bar.

Bradley Poock

Violated NYSE Rule 342(a) by failing to reasonably supervise and control activities of an operations employee under his control who performed supervisory duties in firm’s sales department; caused a violation of NYSE Rule 345(a) by permitting an operations employee under his control to perform supervisory duties of registered representatives without proper registration and/or NYSE approval. Censure and two-week suspension.

Christopher Ahlgrim

Violated NYSE Rule 104 by effecting transactions for Firm’s dealer account that were not reasonably necessary to maintain a fair and orderly market, and failing to effectively represent and execute agency orders entrusted to him; violated NYSE Rule 123B(d) by failing to execute customer orders in accordance with NYSE auction market rules and procedures, including requirements to cross and execute customer orders against each other before buying or selling for Firm’s dealer account. Consent to censure and one-year Floor bar.

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