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An Analysis of SEC and FINRA Enforcement Actions Against #CCOsGoingViral: An Analysis of SEC and FINRA Enforcement Actions Against Compliance Officers, Written for Millennials (and those who work with Millennials) (September 2016 to February 2017) By Brian L. Rubin and Amy Xu Introduction Millennials now constitute the largest portion of the American workforce, according to Pew Research Center analysis of U.S. Census Bureau data.1 The impact of the younger generation is felt, in particular, in the financial services industry as millennials begin to invest their accumulating wealth2 and transition to becoming decision-makers within the financial services sector.3 As such, it is critical that the risks and rewards of ensuring compliance with federal securities laws are explained in language that millennials understand. In an attempt to bridge the divide between securi- ties laws written in the 1930s and a population born between approximately the 1980s and 2000s,4 this article uses hashtags, Internet memes, catch phrases, and other pop culture references to analyze some of the cases that the U.S. Securities and Exchange Brian L. Rubin is Head of Litigation in Commission (SEC) and FINRA have brought against compliance the Washington, D.C. office of Eversheds- officers. Not to be bloviating blowhards,5 but this article may be Sutherland (US), and is the Administrative the thing that baby boomers (who are often organizing paper files) Partner in charge of the Securities Enforce- ment and Litigation Team.* need to decode the hashtag-filled jargon of millennials (who would rather tweet than call). Just as all citizens should stay #woke6 in an ever-changing world, Chief Compliance Officers (CCOs) of broker-dealers (BDs) and investment advisers (IAs) must stay hip with enforcement trends as they carry out the momentous task of helping their firms comply with securities laws and regulations. This article, analyzing cases brought from September 2016 to Feb- ruary 2017, is one in a series7 that provides illuminating analyses, astute insights, and sometimes hilarious tidbits for compliance Amy Xu is an associate in the Washington, professionals (regardless of their biological or psychological age)… 8 DC office of Eversheds-Sutherland (US).** or not ¯\_(ツ)_/¯. ©2017, Brian L. Rubin and Amy Xu PRACTICAL COMPLIANCE & RISK MANAGEMENT FOR THE SECURITIES INDUSTRY | JULY–AUGUST 2017 11 #CCOsGoingViral Failure to Adopt Adequate conduct involved facilitating and engaging in a pattern of ficti- Supervisory Systems tious trading, which included purchasing a security from an institutional customer into the firm’s inventory, and then selling “I am about to do what old people have done throughout the security from the firm’s inventory to another institutional history: call those younger than me lazy, entitled, selfish and customer. The firm’s process for handling trade cancellations shallow. But I have studies! I have statistics! I have quotes permitted him, as the registered representative of record on all from respected academics! Unlike my parents, my grandpar- customer accounts, to initiate, enter, and approve trade cancel- ents and my great-grandparents, I have proof.” lations without independent review or approval. FINRA stated that, “as the Chief Executive Officer and Chief Compliance —Joel Stein (“a member of Gen X, Officer for [the firm], [he] was responsible for ensuring that which invented flannel and Wynona Ryder”),9 [the firm] established and maintained a reasonable supervisory ranting about millennials in Time magazine10 system and WSPs reasonably designed to supervise the firm’s business activities.” As a result, he violated Municipal Securities Whether supported or not, the general consensus about Rulemaking Board (MSRB) Rule G-27 by failing to establish millennials is that they are entitled, lazy, and self-obsessed. reasonable supervisory systems and procedures to prevent Focused entirely on themselves, these “special snowflakes”11 and detect unauthorized trading and discretionary trading. often reject prescribed social norms and supervision. Never- Additionally, he failed to establish a system to provide for the theless, to avoid enforcement actions, firms need to eschew proper review and approval of daily orders and related trade these millennial tendencies and put in place policies and cancellations and to address transaction reporting and order procedures to ensure compliance with federal securities ticket requirements. Based on these actions and others, FINRA regulations (and leave this generational psychobabble analysis found that the individual violated NASD Rules 3010(a) and to other professions). FINRA requires BDs to establish and (b), FINRA Rules 3110(a) and (b) and 2010, and willfully maintain supervisory systems “reasonably designed to achieve violated MSRB Rule G-27 for “failing to establish reasonable compliance” with applicable laws, regulations and rules, supervisory systems and procedures to prevent and detect including written supervisory procedures (WSPs) designed unauthorized trading and discretionary trading, to provide to supervise the business activity of firms.12 FINRA also for the proper review and approval of daily orders and related requires that the supervisory system be “tailored specifically trade cancellations, and to address transaction reporting and to the member’s business.”13 IAs are also required to adopt order ticket requirements.” He was barred from association with and implement written policies and procedures reasonably any FINRA member firm in any capacity. Unfortunately, in designed to prevent violations of applicable laws, regulations describing these violations, FINRA failed to identify whether and rules.14 All IAs must also “[d]esignate an individual (who these violations stemmed from the individual’s role as CEO or is a supervised person) responsible for administering the poli- as CCO. In the future, regulators should emulate the Greatest cies and procedures” that the IA adopts.15 Generation (rather than slack off)17 and provide a more explicit CCOs, sometimes while wearing multiple hats (or backwards analysis as to why people are charged for violations. Such baseball caps), have been sanctioned when firms failed to “estab- specificity would enable the industry and CCOs to understand lish reasonable supervisory systems and procedures to prevent regulatory expectations for compliance professions and to assist and detect unauthorized trading and discretionary trading, them in avoiding personal liability. to provide for the proper review and approval of daily orders If a CCO has adopted the so-called lazy work ethic of mil- and related trade cancellations, and to address transaction lennials and failed to establish supervisory procedures related reporting and order ticket requirements.” In September 2016, to research reports, she or he may be subject to disciplinary an individual who served as Chief Executive Officer (CEO), actions. In October 2016, FINRA accepted the settlement CCO, and Financial and Operations Principal (FinOp), of an individual through a Letter of Acceptance, Waiver and settled a disciplinary action with FINRA through an offer of Consent (AWC) for failure to adopt supervisory procedures settlement related to his fraudulent conduct and his failure related to the firm’s research reports.18 Among other posi- to establish reasonable supervisory systems.16 His fraudulent tions, the individual was the CCO and the firm’s Director of 12 JULY–AUGUST 2017 | PRACTICAL COMPLIANCE & RISK MANAGEMENT FOR THE SECURITIES INDUSTRY #CCOsGoingViral Research. Once again, in the settlement order, FINRA failed settlement of an AMLCO through an AWC for his failure to explain whether the individual was liable due to his actions to adopt supervisory procedures related to the firm’s AML in one role or the other. FINRA stated that he did not adopt compliance program.21 He was responsible for the AML and implement supervisory procedures reasonably designed to compliance program, but failed to develop and implement ensure that the firm’s research reports complied with the dis- one that was reasonably designed to achieve and monitor the closure requirements of NASD Rule 2711. Although the firm firm’s compliance with the requirements of the Bank Secrecy had an automated system that generated required disclosures, Act (“BSA”). The AMLCO did not “have any reports that a system did not exist to ensure that required disclosures were the [f]irm used to monitor low-priced securities, and he failed to develop any internal automated reports, manual reports, or other means to The SEC and FINRA do not shy away from monitor securities received and disbursed to assist the [f]irm in monitoring for sus- charging compliance officers for perceived picious activity.” FINRA stated that the AMLCO failed to ensure that the firm regulatory failures. was conducting reviews of transaction activity to monitor for, detect, and cause actually made. Additionally, the firm did not have a system the reporting of suspicious activity in accounts at the firm. in place to track that it made required disclosures relating to: Due to his inaction, the firm’s AML compliance program (a) the firm or the research analyst’s ownership of the subject was not reasonably designed and could not have been reason- company; (b) whether the firm was a manager of public offer- ably expected to detect and cause the reporting of suspicious ings of the subject company or provided investment banking transactions related to short-term trading of low-priced services; or (c) whether the firm provided non-investment
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