In remarks at the Council of Institutional Investors Spring Conference, SEC Commissioner Hester Peirce highlighted developments in the proxy system, touching on disclosure reform efforts, dual-class shares and mandatory arbitration. As to the SEC rules that empower investors to require that issuers put an investor's proxy proposal on the issuer's ballot for shareholder consideration, Ms. Peirce stated that the current quite low share ownership thresholds "encourage" small shareholders to advance proposals that advance those shareholders' personal or political beliefs, not the beliefs of the

CFTC Division of Enforcement Director James McDonald pledged to enforce Commodity Exchange Act ("CEA") provisions that encompass foreign corrupt practices and issued an Enforcement Advisory on cooperation and self-reporting for violations of the CEA pertaining to foreign corrupt practices. In remarks at the American Bar Association's 2019 National Institute on White Collar Crime, CFTC Director of Enforcement James McDonald said that foreign corruption is the type of misconduct that may lead to price alterations and the undermining of domestic markets. He stated: "we are committed at the CFTC

The successor to a former dually registered investment adviser and broker-dealer agreed to settle SEC charges relating to misleading advisory clients about the cost of its in-house brokerage services. As alleged in the SEC Order, Valley Forge Asset Management, LLC ("Valley Forge") led clients to believe that its affiliated broker charged lower rates than were available elsewhere, even though the broker sometimes actually charged commissions that were over four times more than clients would have paid using alternative brokerage options. The Order also found that Valley Forge benefited from its

A financial services firm agreed to settle FINRA charges for Regulation SHO ( i.e., short sale rule) violations. According to the Letter of Acceptance, Waiver and Consent, the firm, among other things: failed to close out certain "fail-to-deliver" ("FTD") positions from short sales, as required by Rule 204(a), in a timely manner; improperly routed and executed short sale orders by failing first to borrow or to arrange to borrow securities, as required by Rule 204(b); neglected to provide notice - as required by Rule 204(c) - to other broker-dealers for whom the firm cleared and settled trades

An SEC-registered broker-dealer and FINRA member agreed to settle FINRA charges for failing to properly or timely submit 366,428 Reportable Order Events ("ROEs") in one quarter to the Order Audit Trail System ("OATS"), and 58,365 ROEs during a four-month period in the same calendar year, in violation of FINRA Rule 7450 ("Order Data Transmission Requirements"). According to the Letter of Acceptance, Waiver and Consent, Great Point Capital LLC agreed to a censure and to pay $20,000 to settle the charges.