They centered on the regulatory burdens associated with implementing the trust and fiduciary activity's exception's "chiefly compensated" standard and the industry's inability to provide "meaningful" order-taking services for custodial accounts under the safekeeping and custody exception. That type of distinction between violations of sales practice rules and violations of standards that more fundamentally impact markets and trading can be one way to permit regulatory streamlining while protecting the oversight tools necessary to guard the principles of market fairness. In other words, registration promotes baseline levels of integrity among broker-dealers and their personnel. Workforce Succession Planning, ©1997-2020, Strategic Futures Consulting Group, Inc., If a broker-dealer failed to review all of its registered representatives' trades to identify possible insider trading, then a representative may find an opportunity to game the system by obtaining inside information through the broker-dealer while trading on the information through a bank, with neither the bank nor the broker-dealer in a position to properly monitor and act against the abuse. After receiving significant banking industry criticism, however, the Commission tolled the implementation. Indeed, it is common practice among many securities firms to motivate their employees to sell by paying a small base salary and a much larger bonus.

The Association also expressed the view that other law adequately protects investors in tax-deferred accounts, that order-taking as custodian is a "customary" bank activity, and that banks do not initiate securities transactions for these accounts. In August 2002, the Commission engaged in rulemaking to implement two important provisions of the Sarbanes-Oxley Act. This is a situation where a professional is assigned both vertical leadership as well as horizontal leadership responsibilities. I am particularly concerned that companies that are not subject to SEC oversight should not be able to act as unregistered distributors of mutual funds or arms of broker-dealers, thereby circumventing the marketing, customer communications, and other sales practice rules that apply to broker-dealers. The Commission adopted a procedure based on a safe harbor that was designed to meet the "chiefly compensated" test but avoid the account-by-account calculation. There may be even further room for the NASD to apply this rule to dual employee registered representatives in a way that is tailored to enhance regulatory efficiency. Mentoring 1 The Securities and Exchange Commission, as a matter of policy, disclaims responsibility for any private publications or statements by any of its employees. Dual employees of broker-dealers and investment advisers are regulated under this rule.

Dual employees of broker-dealers and investment advisers are regulated under this rule.

This morning I would like to talk to you a bit about the Commission's progress in implementing legislation that goes to the heart of the issue of market integrity: the Sarbanes/Oxley legislation. Accounting scandals, a recession, concerns about terrorists, and a war have depressed market values, significantly reduced volume, and most critically, eroded investor confidence — a rather gloomy picture, but a picture not unique in the history of the Commission.

Finally, with respect to Sarbanes-Oxley, the Commission prepared four studies for Congress that were required by the Act. The dual-hatted role should be time-bound, meaning that it is permitted for a brief, defined period, and no longer. The Commission also will further consider proposed "noisy withdrawal" rules that would require an attorney to withdraw from representation of a company that engaged in material violations, and report such withdrawal to the Commission. One significant aspect of the Sarbanes-Oxley Act was its establishment of the Public Company Accounting Oversight Board to oversee accountants that perform independent audits of public companies. double hatted definition in English dictionary, double hatted meaning, synonyms, see also 'double agent',double back',double bar',double bass'. Mentoring Training Program Matrix Structure The Sarbanes-Oxley Act significantly affected the work of the Commission, particularly given the scope and extent of the rulemaking mandated by that legislation. No evasion of fiduciary regulation of these activities could occur; as such regulation is a condition of this exception. A so-called “dual-hatted” employee serving as both GC and CCO is typically less expensive from a compensation perspective, but the volume of work at a larger or more complex manager may be more than one person can handle. In other words, investors are protected by strong fiduciary principles under fiduciary law. 3 How can your interests be reconciled with the Exchange Act's requirement to protect every securities investor without opening up significant opportunities for regulatory arbitrage or gamesmanship? Strategic Planning It is well known to members of this Association that Gramm-Leach-Bliley repealed the blanket bank exception from broker-dealer registration and replaced it with 15 narrower transactional exceptions. ... that doesn't mean he has to serve him every morning in the Oval Office. By adopting functional regulation, the Gramm-Leach-Bliley Act did not adopt an approach based on entity regulation with multiple competing securities regulators.

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