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The Policy Patty Toolkit Blog covers emerging issues on governance, risk and compliance controls.

This Blog is made available by the Policy Patty Toolkit and the individual postings to this site are for educational purposes and to give you general information of key legal, governance, regulatory and compliance matters and issues. The postings are not intended to provide specific legal advice as to an identified problem or issue. By using this Blog, you understand and acknowledge that there is no attorney client relationship formed between us and should not use this site as a substitute for legal advice from your legal counsel regarding a particular matter.

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A Guide to the role of the Data Protection Officer

Posted on October 19, 2017 at 7:10 PM

The attached blog provides a good overview of the role Data Protection Officer (“DPO”) associated with the EU General Data Protection Regulation (‘GDPR”). Some EU data protection laws do require this role, but finally, the adoption of new rules relating to Privacy Seals by the French Data Protection Authority (CNIL) harmonizes varying requirements. The blog provides the following:

• mandate or legislate for the appointment of the DPO, for example, Ger...

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Broker charged with falsifying records

Posted on October 19, 2017 at 7:45 AM

A broker with Morgan Stanley, Say Nie Sam, agreed to a $5K fine and a 2-month suspension to settle FINRA charges involving falsification of books and records. FINRA alleged that from 2008 to August 2016, Say falsified wire transfer forms totaling $81,300 for a customer by affixing photocopies of the customer’s signature to the wire transfer forms and submitting them to her member firm as authentic documents from the customer. Interestingly, the transactions had been authorized and were ...

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The Deerfield Settlement - Advisers Should Take Notice

Posted on October 17, 2017 at 11:30 AM

The recent SEC settlement involving Deerfield Management Company L.P. (“Deerfield”), a hedge fund and registered investment adviser, raises some interesting issues around the scope of an investment adviser’s duty to create and enforce policies and procedures. Deerfield paid approximately $4.6 million to settle SEC charges that it failed to create and enforce controls reasonably designed to prevent the misuse of material, nonpublic information in violation of Section 204A of ...

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SOX Internal Controls Survey 2017

Posted on October 16, 2017 at 9:20 AM

The 2002 Sarbanes-Oxley Act (“SOX”) was created to improve the quality and reliability of financial reporting functions within each organization. As the SOX & Internal Controls Professionals Group, Moss Adams LLP, and Workiva conducted a survey earlier in this year that polled SOX and internal control professionals from companies representing a wide range of industries, sizes, and SOX process complexity. The survey focused on the state of SOX and internal controls process...

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Compliance Training and the Board(Sep 2017) - A survey by the SCCE and HCA

Posted on October 15, 2017 at 8:00 AM

The Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCA) conducted an anonymous survey to better understand what types of compliance training is delivered to board of directors. The results were recently published and provide as follows:

• While board training is the norm, 28% reported that the board does not receive compliance and ethics-related training, and for publicly traded companies, 34% of respondents indicated no training is ...

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FINRA INVESTOR ALERT - Professional Designations

Posted on October 12, 2017 at 8:30 AM

FINRA issued guidance on selecting and working with financial professionals. The guidance is designed to provide investors with information on how to thoroughly check the claimed credentials of people soliciting their investments to ensure they are not falsifying, exaggerating, or hiding facts about their backgrounds. Both the SEC and FINRA have brought several recent enforcement cases along these lines.

FINRA offers six tips to help you find, and successfully work with, an investment p...

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FTC issues guidance for small businesses on data safeguards

Posted on October 12, 2017 at 7:55 AM

The FTC issued a series of guidance on how small business can protect their data from deletion, hacking, or theft. The information is issued as part of overall efforts to promote awareness during National Cybersecurity Awareness Month. The effort is designed to give access to the resources the FTC has to help you and your employees understand cybersecurity, maintain your business’ computer networks safely, and keep sensitive information protected.

This guidance includes:

...

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SEC approves FINRA consolidated registration rules and requirements

Posted on October 10, 2017 at 2:50 PM

The SEC approved FINRA’s sweeping overhaul of its qualification examinations. Previously, only persons sponsored by a FINRA-regulated firm could take qualification examinations. With the introduction of a “Securities Industry Essentials” examination, FINRA will allow anyone seeking to enter the securities industry whether associated with a member firm or not. Persons who then become affiliated with a FINRA member firm must take a second, more specialized knowledge examinatio...

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NYC's new law on salary histories coming at the end of this month

Posted on October 9, 2017 at 7:45 AM

Starting October 31st in New York City, under an amendment to the city's Human Rights Law, New York City employers can no longer:

• ask job applicants about their salary history;

• research applicants' salary history, such as by asking former employers or searching public records; and

• consider salary history when setting or negotiating applicants’ pay.

The exceptions include:

• internal applicants are not covered by the new law;

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Treasury issues report on recommendations for regulating capital markets

Posted on October 9, 2017 at 7:10 AM

The US Treasury Department report released a report last week setting forth recommendations to overhaul regulation of the capital market. Treasury’s review of the regulatory framework for capital markets identified and a wide range of measures they deemed could promote economic growth. The recommendations in this report are organized in the following categories:

• Promoting access to capital for all types of companies, including small and growing businesses, through reducti...

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