| |
Broker-Dealers
The professionals in the Securities Practice Group are uniquely qualified to assist broker-dealers in today’s complicated and dynamic regulatory environment. We can help broker-dealers achieve a competitive edge while protecting their reputations by developing and implementing effective and efficient compliance and supervisory systems, especially in high risk areas.
We can, for example, assess written supervisory procedures, conduct enterprise-wide compliance reviews, perform focused, in-depth compliance reviews in discrete areas, and act as regulator-mandated independent compliance consultants.
Representative Assignments
- In connection with an inquiry by a federal regulator into a broker-dealer’s alleged manipulative activity in the U.S. Treasury markets, Promontory assisted in an independent review of the broker-dealer’s relevant supervisory, compliance, and other policies and procedures. Our review included assessing all relevant management and compliance reports, monitoring systems, and other controls. Promontory also made recommendations on how to enhance the relevant controls and policies and procedures to achieve industry best practices.
- Using the U.S. sentencing guidelines for organizations, Promontory assessed the effectiveness of a broker-dealer’s compliance and ethics program at (1) exercising due diligence in preventing and detecting improper conduct; and (2) promoting an organizational culture that encourages ethical conduct and a commitment to compliance with the law. Specifically, Promontory evaluated and provided recommendations for improvements related to:
| |
- Establishing necessary and appropriate compliance standards and procedures;
-
Establishing necessary and appropriate oversight and governance structures at the board level, as well as operating and supervisory structures for management;
-
Exercising reasonable care, when giving substantial authority to personnel, to exclude from management any individuals who have engaged in illegal or other acts that conflict with the compliance program;
-
Training and communicating information about the compliance program periodically to directors, officers, and other personnel;
-
Monitoring, auditing, and periodically conducting risk assessments of the effectiveness of the compliance program, as well as facilitating the anonymous or confidential reporting of potential violations;
-
Promoting and enforcing adherence with the compliance program, including providing appropriate incentives for compliance and disciplinary measures for violations; and
-
Responding to and preventing recurring unethical conduct.
|
* * *
For more information regarding the Promontory Securities Practice Group, please contact Kathleen Hamm, Managing Director, at (202) 384-1022 or khamm@promontory.com
|
|
