Caution: SEC Looks at More Than Just Policies and Procedures for Whistleblower Violations

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Earlier this month, Health Net Inc. agreed to pay a $340,000 penalty for illegally using severance agreements that required employees leaving the company to waive their right to obtain monetary awards from the SEC’s whistleblower program.  According to the SEC order, by doing this, the California-based health insurance provider directly targeted the Congress-authorized program.

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Internal Control Gaps at Apollo Advisers

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Earlier this week, four private fund advisers affiliated with Apollo Global Management agreed to a $52.7 million settlement.  During an investigation by the SEC, the advisers were found to have misled fund investors about fees and a loan agreement, as well as failed to supervise a senior partner who charged personal expenses to the fund.

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Rule Making By Enforcement: Churning

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Brad Bennett, FINRA’s Executive Vice President and Chief of Enforcement, said, “A key element of retail investor protection is the aggressive pursuit of brokers who churn and excessively trade customer accounts.  FINRA has no tolerance for brokers who place commissions ahead of what is suitable and appropriate for their customers.” (FINRA News Release August 6, 2015.)

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The SEC Halts Securities Fraud Scheme

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Earlier this week, the SEC won a court-ordered asset freeze of two former brokers, James Brennan III and Douglas Dyer, and their company Broad Street Ventures. The former brokers, both of whom have disciplinary histories with FINRA and state regulators, allegedly raised more than $5 million from investors by selling purported shares in eight similarly named companies. Continue reading

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Updated Investor Alert for Seniors: Five Red Flags of Investment Fraud

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Although many believe in upholding the old adage to respect one’s elders, there are others who seek to take advantage of older Americans, targeting them for investment fraud.  Unfortunately, many senior citizens fall victim to these scams if not fully informed.

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Selecting an Expert Witness

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Occasionally, in the event a case requires litigation, legal counsel may request the assistance of one or more expert witnesses.  As specialists in their field, these experts can provide advanced knowledge, skill, experience, training and/or education that can assist with the case, including determining whether or not going to trial is necessary.

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Citigroup Fined by SEC for Providing Incomplete ‘Blue Sheet’ Data

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On July 12, 2016, after undergoing an investigation by the Securities and Exchange Commission (SEC) regarding a computer coding error that caused Citigroup Global Markets to provide the agency with incomplete “blue sheet” information about trades it executed from May 1999 to April 2014, the Manhattan-based investment banking and financial services firm agreed to admit wrongdoing and pay a $7 million penalty, the largest penalty to date for blue sheet violations.

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