In a recent decision released by the SEC, an administrative law judge ordered the dismissal of sanctions against a former bank compliance officer. The dismissal stemmed from the SEC's finding that the compliance officer had aided and abetted violations of the law willfully, though not with the intent to profit or to injure anyone. Initially, the former officer was tasked with reviewing an employee's investments in a company that was acquired shortly thereafter. A year later, the SEC charged the employee with insider trading. After the employee was charged, the compliance officer revisited the

The Office of the Comptroller of the Currency ("OCC") named Linda Cunningham as its first Chief Risk Officer and Stephen Warren as its next Chief Information Officer. Ms. Cunningham will lead the agency's newly created Office of Enterprise Risk Management as well as its Enterprise Risk Committee. She also will participate in the OCC Executive Committee, National Risk Committee and other significant committees in order to promote a broader view of enterprise risks. Mr. Warren will lead all of the OCC's information technology programs. He also will support the agency's mission of ensuring the

The CFTC issued an order requiring a firm that registered as a futures commission merchant ("FCM") and registered provisionally as a swap dealer to pay a penalty for failing to maintain sufficient U.S. dollars in segregated accounts in the United States. The Order found that the firm did not have in place adequate procedures to comply with the currency denomination requirements for cleared swaps customer collateral and did not train and supervise its personnel to ensure compliance with CFTC Regulations. As a result the CFTC found that the firm "failed to supervise diligently its officers

In a study titled "What Drives Dodd-Frank Act Compliance Cost for Private Funds?" University of St. Thomas School of Law Associate Professor Wulf A. Kaal assessed the extent to which Dodd-Frank compliance costs are forcing smaller private investment fund advisers out of the market. Professor Kaal's study found that compliance costs have a strong fixed cost element; i.e., the advisers to smaller funds pay more in compliance costs proportionately than the advisers to larger funds must pay. According to Professor Kaal, the findings of the study suggest that (i) the Dodd-Frank compliance costs

The North American Securities Administrators Association ("NASAA") announced that its new Electronic Filing Depository ("EFD") has been used to facilitate more than 10,000 notice filings with state securities regulators since its launch less than eight months ago. EFD is an online system that allows issuers to submit a Form D for Regulation D, Rule 506 offerings to state securities regulators, as well as pay related fees. The EFD Web site also enables the public to search and view Form D filings made with state securities regulators through EFD. Although the EFD system currently is limited to