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'Chilled off box' Steyn threatens 'pure company' in checks in opposition t Australia | killexams.com existent Questions and Pass4sure dumps

Sydney, Nov. 2 (ANI): South Africa quick bowler Dale Steyn is gearing up to convey some warmth on the domain as he prepares for the three-examine sequence in opposition t Australia starting subsequent week.

The 29-yr-ancient says that whereas he's light-mannered and chilled out off the container, when it involves the online game, he capability absolute enterprise.

"I believe cricket brings out a greater aggressive side in me in complete honesty. that may deliver out the furious in anyone. I consider off the domain i'm fairly chilled however on the box it subsist complete business," the Sydney Morning Herald stories.

in line with the paper, Steyn, who's the excellent-ranked bowler on the planet, and the protagonist amongst a trio of Proteas quicks, however, feels he is not the example paceman on the planet, but says that he has obviously completed well for the Proteas.

"It does not necessarily hint that i am the surest and most knowledgeable bowler in the world. I believe there are likely greater bowlers available. I believe i am some of the guys which beget normally performed for South Africa and carried out neatly," he noted.

Steyn likewise observed that his success in the activity is fully on account of the manner he has been dealt with by using South Africa, the paper mentioned.

"'I believe i've been managed neatly. I've simplest performed a handful of one-day internationals - I've simplest played relish eighty one-day video games [he has played 66]. For a person that is been taking section in so long as I beget in my scrutinize at various profession I probably should beget performed double that at the least. in order that they've managed me bloody neatly. i am pretty stoked about that," he referred to. (ANI)


Bombardier's CEO Discusses Q3 2013 results - revenue designation Transcript | killexams.com existent Questions and Pass4sure dumps

No influence discovered, are trying original key phrase!EBIT margin is at 6% compared to 6.three% remaining 12 months specially as a result of dwindle margin ... How is the company atmosphere at the second for giant company tests? or not it's good. The international has acquired an excellent recognition, ...

IWill KK266Plus KT133A Motherboard evaluation | killexams.com existent Questions and Pass4sure dumps

Ziff Davis Media's company and content material introduction Winstone benchmarks are used to simulate "true-world" utility performance...

.business WINSTONE:

enterprise Winstone runs a number of ordinary "office-classification" purposes via a collection of scripted activities. monitors how lengthy the system takes to complete those activities and calculates it subsist efficiency ratings for that reason.

As that you can see, the Iwill KK266Plus edged out the Shuttle AK11 via only a hair.  Seeing business Winstone scores >40 on 1GHz., windows ME programs is awfully first rate.  Let's flood on to the more "stressing" content material creation checks and discern what happens...

content material introduction WINSTONE:

content material introduction exams are similar to the business tests, but encompass some extra "bandwidth hungry" apps relish Adobe highest trait 5.1 and Photoshop 5.5.

The efficiency between the two test systems is essentially similar, with a temper performance competencies going to the Iwill board.  performance differences this tiny could subsist indiscernible in every day use.

The Iwill KK266Plus is a top performer in it's category.  The Iwill KK266Plus become very tenacious right through checking out, and managed to outperform an analogous board from Shuttle in each examine they ran.  although the efficiency turned into respectable...very first rate considering that that you could find this board for roughly $100US...settling for a standard SDRAM based mostly motherboard at the second isn't beneficial.  If i used to subsist reviewing this board 6 months in the past, i might truly subsist singing it's praises, but with the expenditures of DDR RAM as low as they're, there is not any compelling motive no longer to migrate to DDR.  in case you already beget a boatload of regular SDRAM that you're not willing to half with, and are looking for a pretty cogent motherboard, then by using complete aptitude believe the Iwill KK266Plus, it's a brilliant product, however original gadget builders really should still subsist looking for a DDR solution. They give the Iwill KK266Plus a HotHardware warmth Meter ranking of...

suppose you find out about this hardware stuff?  Then bag into the forum and strut your Stuff!

 


Series6 NASD progression 6

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Series6 exam Dumps Source : NASD progression 6

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practice test : 200 existent Questions

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FINRA Publishes Its Annual Report on Examination Findings | killexams.com existent questions and Pass4sure dumps

Thursday, December 20, 2018

On December 7, FINRA published its Report on 2018 Examination Findings1 (the "Report"). This is the second year that FINRA issued a summary of its observations from recent examinations. This Report, read in conjunction with FINRA's Annual Regulatory and Examination Priorities Letter2, is worthy of attention as a roadmap of FINRA's priorities, with highlights based on significance, frequency and impact on investors and the markets. This year the Report focused on suitability for retail customers, fixed income mark-up disclosures, reasonable diligence for private placements and mistreat of authority. The Report likewise discussed a case study that highlights examination findings from a sweep of volatility-linked products and advised on concerns in additional regulatory areas.

Highlighted Observations Suitability for Retail Customers

The Report highlighted several examination findings under its suitability rule, 21113, notably of powerful interest for FINRA and the industry as it relates to the firm-investor relationship and investor protection. Proposed Regulation Best Interest raises similar issues as those raised in the examination findings. The Report discussed situations where registered representatives failed adequately to consider the appropriate factors, for case financial situation, investment suffer and investment objectives, in determining if an investment is suitable for an individual. 2018 was no exception to FINRA's ongoing concern with unsuitable recommendations in complex products and the Report identified leveraged and inverse exchange-traded products (ETPs), including exchange-traded funds (ETFs) and notes (ETNs). The Report likewise noted sales drill abuses in illiquid securities (such as non-listed REITs), variable annuities, mutual fund partake classes and Unit Investment Trusts (UITs). The Report examined overconcentration, immoderate trading and unsuitable variable annuity recommendations.

As a resource for firms to strengthen their compliance programs, the Report included examples of sound supervisory practices. For example, some firms implemented controls restricting or implementing a "hard block" prohibiting recommendations of products for sure investors. Other firms required training in tall risk or complex products prior to allowing its sales compel to recommend the investment. Emphasizing the second of using technology and basic communication techniques, sure firms developed parameters for trading volume and cost to identify and preclude immoderate trading, and some firms made telephone calls or sent particular activity letters to customers whose accounts breached the firm's trading thresholds.

This year FINRA conducted a targeted examination of Volatility-Linked Products to assess firms' supervision of suitability obligations to retail customers.4 The Report identified specific comprehensive controls seen at some firms, such as stringent pre-qualification criteria. The Report likewise raised a warning about inadequate practices observed regarding suitability, due diligence and systems and controls.

Fixed Income Mark-Up Disclosure

On May 14, FINRA and the Municipal Securities Rulemaking Board (MSRB) implemented amendments to FINRA Rule 2232 (Customer Confirmations)5 and MSRB Rule G-156, which require firms to provide additional transaction-related and mark-up/mark-down information to retail customers for sure trades in corporate, agency and municipal debt securities.

In conducting examinations to assess firms' compliance with these original rules, the Report identified several challenges, including: failure to enter complete information into the firm's systems, inadequate disclosures for trades conducted on an agency basis, failure to provide discloses for structured notes, incorrect designation of institutional accounts, and improper security-specific hyperlinks. One concept that ranged across several deficiencies is the "percentage of prevalent market price" (PMP). Disclosed mark-ups and mark-downs must subsist expressed as both a total dollar amount for the transaction and a PMP. The Report found inaccurate disclosures because of firms' improper adjustments to PMP of the brokers' sales credit from the mark-up and vendors' failure to identify the redress PMP.

Reasonable Diligence for Private Placement

The Report discussed the best and inadequate practices in firms' due diligence reviews required by reasonable basis suitability obligations for private placements. On the positive side, the Report found that firms that performed meaningful due diligence conducted independent research, verified information, identified red flags and created a due diligence committee. Firms that engaged in offerings involving issuers that were related to the arduous created a diligence process that identified and mitigated the potential conflicts.

The Report reminded firms to document the "process and results" of their due diligence analysis. Among the insufficient due diligence findings were firms that conducted no reasonable due diligence, over-relied on third parties to prepare the due diligence without evaluation or attention to red flags, and used conflicted third-party due diligence associated with the issuers.

Abuse of Authority

Certain trading relationships, such as discretionary trading7 or Powers of Attorney, allow brokers to act on their customers' authority. FINRA examined how firms' implement appropriate controls to manage the risks, such as unsuitable or immoderate trading, associated with these roles. The Report found that some firms implemented reasonable controls, for example, through established automated systems to detect immoderate trading. Others used regular attestations from brokers or customers to confirm the relationship.

The Report identified situations where firms or brokers exposed its investors to risks or did not implement reasonable controls to mitigate the risks. The Report commented on brokers who exercised control in investors' accounts without the investors' written authorization, or after that authority had expired. sure brokers mismarked order tickets to obscure the want of trading authority and others made unsuitable statements on their firms' compliance questionnaires. Always concerned about senior investors, FINRA warned of brokers who convinced senior citizens to designation them as trustees or beneficiaries in their accounts.

Additional Observations

The Report likewise mentioned ten subject areas.

Anti-Money Laundering

FINRA Rule 33108 the Bank Secrecy Act (BSA)9 and US Department of the Treasury regulations specify firms' obligations in anti-money laundering compliance. Among the Treasury regulations, FinCEN's Customer Due Diligence (CDD) rule went into outcome on May 11, requiring that firms identify advantageous owners, understand the nature and purpose of customer accounts, conduct ongoing monitoring of customer accounts to identify and report suspicious transactions, and update customer information on a risk related basis.

The Report found inadequacies in some firms' overall AML program and specifically three areas of concern:

  • The Report noted increased trading within firms by alien entities in similar low-float and low-priced securities. Firms failed to question the commonality of ownership status of these alien legal entity accounts.

  • Some firms failed to document decisions whether or not to file Suspicious Activity Reports (SARs) or used exception reports that did not document reviews into potentially suspicious activity.

  • Other firms failed to comply with Section 314(a) of the USA PATRIOT Act10, and did not conduct reviews of FinCEN's Secure Information Sharing System (SISS).

  • Accuracy of Net Capital Computations

    The Report found that sure firms maintained insufficient documentation regarding expense-sharing agreements when third parties agreed to assume responsibility for payment of the firms' expenses. Other firms applied incorrect haircuts to sure securities or miscalculated operational charges in calculating its net capital under Securities Exchange Act Rule 15c3-1.11

    Liquidity

    FINRA Regulatory Notice 15-3312 describes the requirements for firms' liquidity risk management program. The Report identified that some firms' stress test analyses were limited to a single-time horizon while other firms failed to incorporate the results of the stress test into their business models.

    Segregation of Client Assets

    The Report identified lapses in compliance with aspects of Securities Exchange Act Rule 15c3-3.13 The Report noted that firms should subsist more diligent in timely forwarding customer checks to their clearing firms. Some firms improperly used customer "fully paid for" or excess-margin securities to fund their operations and some firms incorrectly calculated its reserve formula requirements.

    Operations Professional Registration

    FINRA Rule 1230 (Associated Persons Exempt from Registration)14 and FINRA Regulatory Notice 11-3315 situation that sure arduous personnel engaged in "back office" covered functions must qualify and register as Operations Professionals.16 The Report identified that some firms continue to allow unregistered employees to engage in activities that require registrations, for case approving general leger journal entries, supervising financial functions and approving business requirements.

    Customer Confirmations

    The Report identified firms that failed to maintain adequate supervisory programs for transactions with customers relating to confirmations under Securities Exchange Act Rule 10b-1017 and FINRA Rule 2232 (Customer Confirmations).18 The Report highlighted challenges such as overall inadequate supervision or inaccurate disclosures of trading capacity, compensation, uninterested charge and market maker status.

    DBAs and Communications With the Public

    The Report found that some brokers used a "doing business as" or "DBA" name, to conceal outside business activities that were not disclosed as FINRA Rule 3270 (Outside business Activities of Registered Persons).19 The Report observed that some firms did not maintain reasonable supervision over the disburse of DBA names, including in its compliance with FINRA Rule 2210 (Communications with the Public).20 Some brokers' retail communications and arduous correspondence included the brokers' DBA designation but not the firm's designation or that the securities were offered through the firm. Other brokers' websites failed to contain an appropriate link or reference to FINRA's BrokerCheck.

    Best Execution

    FINRA Rule 5310 (Best Execution and Interpositioning)21 lays out the obligations for best execution in equities, options and fixed income securities trading. Examples of challenges the Report identified in 2018 were failing to assess the execution trait of competing markets, failing to review order types and failing to evaluate required factors such as accelerate of execution, charge improvement and the likelihood of execution of limit orders.

    TRACE Reporting

    FINRA Rule 6700 progression (Trade Reporting and Compliance Engine (TRACE)22 states the requirements for transaction reporting, including the requirement implemented in 2017 to report on sure Treasury transactions. The Report found that some firms failed to beget reasonable supervisory systems to address track reporting. The Report identified late and inaccurate reporting as well as a failure to beget a system to determine if a transaction is track eligible.

    Market Access Controls

    A arduous that provides or uses market access must comply with Securities Exchange Act Rule 15c3-5 (Market Access Rule).23 In its examination of this provision, the Report found that some firms mug difficulties with intra-day adjustment of pre-trade financial thresholds and oversight of third-party vendors.

    Conclusion

    Upon joining, FINRA's president and chief executive officer, Robert Cook embarked on a 360 listening tour. The Report accomplishes two of his stated goals as a result of that tour: increased transparency and providing member firms better tools to improve their regulatory compliance.

    1 FINRA, "Report on FINRA Examination Findings," 2018.

    2 FINRA, "2018 Annual Regulatory and Examination Priorities Letter," January 2018.

    3 FINRA Rule 2111. Suitability.

    4 FINRA, "Targeted Examination note on VIX-Linked Products," April 2018.

    5 FINRA Rule 2232.

    6 MSRB Rule G-15.

    7 FINRA Rule 2510. Discretionary Accounts.

    8 FINRA Rule 3310. Anti-Money Laundering Compliance Program.

    9 9 Bank Secrecy Act, Title 31—Money and Finance.

    10 USA PATRIOT Act, Section 314(b).

    11 Securities Exchange Act Rule 15c3-1, Net Capital Requirements for Brokers or Dealers.

    12 FINRA, "Regulatory Notice 15-33," September 2015.

    13 Securities Exchange Act Rule 15c3-3, Reserve Requirements for Margin related to Security Futures Products.

    14 FINRA Rule 1230. Associated Persons Exempt from Registration.

    15 FINRA, "Regulatory Notice 11-33," July 2011.

    16 FINRA, "Regulatory Notice 11-33," July 2011.

    17 Securities Exchange Act Rule 10b-10, Confirmation Requirements for Transactions of Security Futures Products Effected in Futures Accounts.

    18 FINRA Rule 2232. Customer Confirmations.

    19 FINRA Rule 3270. Outside business Activities of Registered Persons.

    20 FINRA Rule 2210. Communications with the Public.

    21 FINRA Rule 5310. Best Execution and Interpositioning.

    22 FINRA Rule 6700 Series. Trade Reporting and Compliance Engine (TRACE).

    23 Securities Exchange Act Release No. 63241, 75 Fed. Reg. 69792, November 3, 2010.


    Guardians of the (Compliance) Galaxy: Lessons from SEC and FINRA Enforcement | killexams.com existent questions and Pass4sure dumps

    Introduction

    While the heroes of previous generations of moviegoers included Will Kane in the ‘50s, Atticus Finch in the ‘60s, Rocky Balboa in the ‘70s, Indiana Jones in the ‘80s, Clarice Starling in the ‘90s, and Erin Brockovich in the 2000s,3 today’s fans are interested in a far different benevolent of hero. They want to watch and admire people who are Hardworking relish Diana (Wonder Woman), Energetic relish Jay Garrick (the Flash), liable relish Peter Parker (Spiderman), Organized relish Charles Francis Xavier (Professor X), Erudite relish Anthony Edward “Tony” Stark (Iron Man), and a Self-starter like Bruce Wayne (Batman).4 (“HEROES,” bag it?) In other words, people relish (drumroll please) chief compliance officers or CCOs.

    The official tagline for the movie Guardians of the Galaxy is, “All heroes must start somewhere.”5 That statement is cogent not only for movie superheroes, but likewise for their real-life CCO superheroes. These men and women may not wear magic capes, don futuristic armor, or waive supernatural hammers, but they execute serve as generals in a firm’s army of compliance professionals (even if they are an army of one). These everyday superheroes carry a hefty burden: protecting their firms from regulatory mayhem. In doing so, they bewitch on the risk that their own personal actions (or inactions), no matter how heroic, will subsist highly scrutinized by the regulators.

    This article, one in a series,6 analyzes SEC and FINRA enforcement cases from December 2017 to September 2018 brought against compliance officers who lost their ethical compass (or perhaps ran into Kryptonite). As you’ll discern (although not in IMAX or 70 mm), the cases and the accompanying analysis provide insights and (hopefully) a bit of heroic comic relief regarding conduct that prevented compliance officers from achieving their cogent superhero greatness. 

    Failure to Adopt Adequate Supervisory Systems\

    Spiderman

    “[I]n this world, with powerful power there must likewise come—great responsibility.” – Benjamin Parker (Uncle Ben)

    Chief compliance officers play an integral role in combatting the forces of evil (while at the selfsame time maintaining a safe and sound compliance and supervisory system and helping to ensure that firms continue to linger in business and thrive). Given the regulatory requirements, as well as the CCO’s position within firm, it is usually the CCO who controls the firm’s policies, procedures, and overall compliance structure. And with that control comes—you guessed it—great responsibility. 

    To serve ensure that firms don’t completely disengage their regulatory defenses, FINRA requires broker-dealers (BDs) to establish and maintain adequate supervisory systems that are “reasonably designed to achieve compliance” with the applicable laws, regulations and rules, and to establish written supervisory procedures (WSPs) that are designed to supervise the business activities of firms.8 FINRA likewise requires that a firm’s supervisory system subsist “tailored specifically to the member’s business.”9 Additionally, FINRA rules require the designation of at least one CCO, who serves as the primary advisor to the member on its overall compliance scheme and rules, policies and procedures.10 Investment advisers (IAs) are required to adopt and implement written policies and procedures reasonably designed to preclude violations of applicable laws, regulations and rules.11 Investment advisers must likewise “[d]esignate an individual (who is a supervised person) liable for administering the policies and procedures” that the IA adopts.12

    When heroes revolve unheroic, regulators sometimes hammer them with the strength of Thor (or something immediate to that). For example, in December 2017, a FINRA hearing panel barred a CCO for various misdeeds, among them failing to update the firm’s procedures to reflect restrictions that FINRA had imposed upon an individual as section of interim FINRA Continuing Membership Application restrictions.13 The CCO was sanctioned because the Hearing Panel found that the CCO was the only individual at the arduous with authority to revise the WSPs. 

    to revise the WSPs. In July 2018, the National Adjudicatory Council (NAC) found that a BD CCO failed to establish and maintain supervisory systems and WSPs that were tailored to the firm’s microcap liquidation business.14 In June 2017, the Hearing Panel suspended the CCO for two years and ordered a fine of $50,000, and on appeal, the NAC affirmed. The firm’s May 2013 WSPs required that the CCO subsist liable for establishing procedures reasonably designed to ensure that a stock certificate was correctly issued and owned by the customer. It likewise required the CCO to establish procedures that ensure that a resale of a security was “made in reasonable reliance on an exemption from registration,” specifying that the CCO was liable for “developing and implementing policies and procedures that provide for the review, approval and resale of rule 144 transactions.” 

    The CCO argued on appeal that he had no responsibilities for the WSPs for Rule 144 transactions because the policies did not reflect the firm’s practice. He likewise argued that the May 2014 WSPs stated that the general Principal was liable for the Rule 144 policies and procedures, and the WSPs defined general Principal as the “Management Committee.” The May 2014 WSPs listed four individuals as the Management Committee, including the CCO. The Committee was disbanded in May and June 2014, but the CCO had not transferred his responsibility. The NAC found that once he became CCO, he had the authority and responsibility under the WSPs to update them with the firm’s assignment of responsibilities, and he failed to execute so. He likewise did not designation another principal as being liable for maintaining the WSPs for the Rule 144 transactions. 

    The NAC likewise found that the CCO failed to maintain a supervisory system and adequate WSPs related to the firm’s microcap liquidation business because he failed to implement policies for the review, approval, and resale of Rule 144 transactions. The CCO failed to tailor the policies and address the associated risks with the firm’s primary business function, which was the deposit and liquidation of microcap securities. The NAC accordingly suspended the CCO from associating with any FINRA member arduous for two years and fined him $50,000. The NAC noted that the violations were egregious and that the CCO “demonstrated failure to treasure the extent and seriousness of the responsibilities he took on,” which warranted “significant sanctions in excess of the Guidelines recommended range.” 

    Takeaway: You don’t requisite an infinity stone to know that regulators may impose sanctions on CCOs who fail to follow, develop, and update their firms’ procedures. This is especially vital where the regulator has imposed restrictions on the firm, or where the arduous employs individuals who are subject to plans of heightened supervision that compliance officers must draft (e.g., statutorily disqualified individuals, individuals with a history of customer complaints, etc.).15

    Insufficient Disclosures

    Captain America: Civil War

    “Okay, anybody on their side hiding any shocking and grotesque abilities they’d relish to disclose?” – Iron Man16\

    Disclosures are vital not only for superheroes. They are likewise vital for firms trying to ensure that they aren’t making misrepresentations or omitting to situation material facts. At times, compliance officers play a role in their firms’ disclosures, including those related to conflicts of interest. (It goes without epigram that superheroes are always addressing conflicts of interest, whether it’s regarding using their superpowers or showing restraint or disclosing their secrets or remaining incognito.) 

    This article, one in a series, analyzes SEC and FINRA enforcement cases from December 2017 to September 2018 brought against compliance officers who lost their ethical compass (or perhaps ran into Kryptonite)

    Chief compliance officers may subsist found liable in connection with their firms’ inaccurate disclosures. For example, in April 2018, the SEC accepted an present of settlement from an individual who played many roles at his firm, including acting as CCO.17 In that capacity, he signed and filed Forms ADV, falsely representing that his arduous had the requisite assets under management to register as an IA, which requires a sure amount of assets under management (AUM). In January 2005, the CCO filed an initial contour ADV representing that the arduous would subsist eligible for SEC registration within 120 days. Four months later, the CCO filed a supplemental contour ADV falsely representing that the arduous had AUM of $25 million or more. The CCO repeated the selfsame representations over the course of five years, later falsely stating that the AUM was more than $100 million. In reality, the arduous did not beget the requisite AUM to register as an investment adviser. The SEC charged the CCO and the arduous with violating Sections 203A and 207 of the Advisers Act, ordered the CCO to pay a civil money penalty of $20,000, and barred him from the industry for a year. 

    Takeaway: Chief compliance officers may subsist sanctioned if they fail to file complete and accurate disclosures. No matter the regulator, failure to disclose conflicts may lead to a less than Marvel-ous outcome for CCOs and firms alike. 

    Policies and Procedures Related to Performance

    Avengers: Infinity War

    “I went forward in time to discern complete the viable outcomes of the present situation.” – Dr. Strange18

    Like Dr. Strange, when regulators are evaluating statements, they execute so with the futuristic benefit of 20-20 hindsight. Thus, they beget no requisite for Clark Kent’s glasses or Superman’s x-ray vision. Instead, if a statement is too cogent to believe after-the-fact, they may investigate the basis for that statement, which could result in an enforcement action. 

    Regulators often bring cases against firms or representatives for making misleading statements or omitting to situation material facts. Sometimes, compliance officers bag implicated for their firms’ statements. For example, in April 2018, through a settled action, the SEC alleged that an individual who was president, CCO, and an 80% owner of an investment adviser caused his arduous to build willful fraudulent statements in advertisements, written materials, presentations, seminars, websites, radio shows, and weekly updates delivered to clients regarding the firm’s hypothetical algorithmic trading activity.19 As CCO, the individual was liable for the firm’s policies and procedures. The SEC alleged that the arduous failed to adopt and implement policies and procedures reasonably designed to preclude violations of the Advisers Act in connection with its advertisements. The arduous advertised performance without disclosing that the returns were hypothetical, back-tested performance results. In other words, the arduous went forward and backward in time to paint a rosier picture of the model’s performance. (Now if that isn’t a Doctor eerie move, they don’t know what is.) Unfortunately, the CCO did not disburse his time traveling powers for cogent (unlike, say, in the Back to the Future movies, which involved no actual superheroes). The SEC permanently barred the CCO and assessed a $75,000 penalty against him. 

    Takeaway: Chief compliance officers may subsist held liable for failing to implement appropriate policies and procedures in many different areas, including in connection with performance statements. 

    Anti-Money Laundering

    Guardians of the Galaxy “Groot:

    I am Groot.” “Rocket Raccoon: Asleep for the danger, awake for the money, as per frickin’ usual.”20

    Groot may not subsist CCO material but staying awake for the money is one vital prerequisite for an anti-money laundering compliance officer (AMLCO). Of course, there are others, as demonstrated by the cases below. 

    In May 2018, through an present of Settlement, the SEC alleged that a BD’s CCO, who likewise served as the firm’s AML officer, failed to file Suspicious Activity Reports (SARs) and ignored AML due diligence responsibilities related to sure fraudulent penny stock transactions.21 Specifically, seven customers sold more than 12.5 billion shares of penny stocks, often in large volumes, and each conducted at least one transaction where the sale was more than 50% of the sales volume during the solitary trading day. Four of the seven customers had at least one transaction where the sales exceeded 70% of the sales volume. Under the firm’s AML program, the CCO/ AMLCO had the responsibility to file the SARs. The SEC found that he should beget looked for patterns of suspicious activity and flagged potentially problematic transactions. Due to his failures, he was barred from the industry for three years, barred from participating in any offering of penny stocks, and ordered to pay a penalty of $15,000.

    In July 2018, the SEC  accepted an present of Settlement submitted by the AMLCO of a dually registered BD/IA for failures to file SARs on hundreds of suspicious transactions involving low-priced securities.22 arduous customers transacted low-priced securities through the firm, but the shares were custodied at another firm. The SEC found that the AMLCO failed to review flagged transactions for potential market manipulation. Specifically, the AMLCO failed to file SARs where the customers: (i) sold large numbers of lowpriced securities comprising large percentages of issuers’ daily trading volume and outstanding float; (ii) traded shares of issuers that changed names and business lines; (iii) sold large shares of low-priced securities during periods of increases in charge and volume; and (iv) traded in shares of issuers with microscopic or no market activity. This activity caused the clearing arduous to issue alerts to the AMLCO. However, despite the alerts, the AMLCO failed to file SARs and failed to capitulate any written analysis or otherwise demonstrate that he had considered filing SARs for these transactions. The SEC ordered the AMLCO to pay a civil penalty of $20,000. Takeaway: Anti-money laundering compliance officers may subsist sanctioned if they fail to identify red flags and file appropriate SARs. Where suspicious transactions are flagged, AMLCOs may requisite to provide analyses or demonstrate that they considered filing SARs. 

    Failure to result Written Supervisory Procedures

    Be a Bathroom Superhero (book for parents and children) (found after much googling)

    “Be a Bathroom Superhero – Teaching bathroom rules and procedures”23

    While some superheroes (apparently) requisite to learn bathroom rules and procedures, some of them (presumably) beget already scholarly how to result mandates when their superhero qualities advance out. (Or at least they don’t build movies about the “learning the bathroom” years.)

    Compliance officers likewise requisite to learn how to result the rules, particularly rules set forth in written supervisory procedures (WSPs). And, if they don’t, their careers might subsist flushed down the toilet. (Sorry about that.) The abovereferenced July 2018 present of Settlement provides an example.24 The SEC alleged that the AMLCO failed to result WSPs related to reporting known or suspected violations of AML policies and other suspected violations or crimes. The firm’s WSPs expressly identified transactions that could warrant a SAR filing. For example, the WSPs identified specific red flags for trading in low-priced securities, trading that constituted a substantial portion of trading for the day in a particular security, sudden spikes in investor demand and a rising charge in thinly traded or low-priced securities, or various other forms of suspicious transactions. The WSPs expressly tasked the AMLCO as being liable for deciding whether the arduous needed to file a SAR. However, the SEC alleged that, although the AMLCO became cognizant of transactions that were specifically red-flagged 

    in the WSPs and he was alerted by clearing firms that sure transactions appeared suspicious, he failed to provide any written analysis or demonstrate that he had considered filing SARs for these types of transactions. The SEC ordered the AMLCO to pay a civil penalty of $20,000 due to his failure to result the WSPs related to SARs. Takeaway: Anti-money laundering compliance officers (and other compliance officers) may subsist sanctioned for failing to result WSPs. This is an issue where the WSPs specifically contour tasks that must subsist taken when sure conduct arises. 

    Chief compliance officers play an integral role in combatting the forces of evil (while at the selfsame time maintaining a safe and sound compliance and supervisory system and helping to ensure that firms continue to linger in business and thrive).

    Custody Rule

    The gloomy Knight

    “Batman/Bruce Wayne: What did you do?”

    “Joker: I took Gotham’s white knight and I brought him down to their level. It wasn’t hard. You see, madness, as you know, is relish gravity. complete it takes is a microscopic push! [the Joker laughs hysterically as Batman races off and the cops advance to bewitch the Joker into custody].”25

    The SEC’s custody rule is Rule 206(4)-2 of the Advisers Act.26 It is a very vital rule, although Gothamites might bicker that it’s not quite as significant as taking the Joker into police custody. Nonetheless, the SEC may hold CCOs liable for their firms’ failure to comply with the rule.The custody rule requires sure types of verification of assets for registered IAs with custody of client securities or funds. In April 2018, through an present of Settlement with an IA and an individual who was the firm’s owner, managing member and CCO, the SEC found, among other things, that the arduous failed to comply with the custody rule because it allegedly failed to provide quarterly statements to clients and failed to systematize a astound verification of client assets by an independent public accountant, as required under the rule.27 Since the CCO was liable for the company’s compliance procedures (which required him to know that the arduous failed to provide account statements or systematize for an annual verification of the client funds and securities by an independent public accountant), the SEC charged him and the company with violating the custody rule. The SEC ordered the CCO to pay a civil penalty of $20,000 and suspended him from the industry for one year. 

    Takeaway: Chief compliance officers may be sanctioned for conduct related to the custody rule if they beget responsibility for compliance with that rule.

    Conclusion 

    Guardians of the Galaxy

    Peter Quill: Well, on my planet, they beget a legend about people relish you. It’s called Footloose. And in it, a powerful hero, named Kevin Bacon, teaches an entire city replete of people with sticks up their butts that, dancing, well, is the greatest thing there is. Gamora: We’re just relish Kevin Bacon.28 

    Because compliance officers can’t complete subsist superheroes relish Kevin Bacon, to try to avoid disciplinary actions (and having sticks up their butts), they may want to review regulatory speeches and notices, anatomize enforcement actions, attend conferences, study their firms’ procedures, read compliance periodicals and articles relish this one, and occasionally discern a superhero movie. And remember, not complete superheroes wear capes (although they know of several CCOs who do).29


    Priority Income Fund, Inc. Announces the Declaration of Distributions on Shares of the Fund’s 6.375% progression A Term Preferred Stock due 2025 and 6.25% progression B Term Preferred ... | killexams.com existent questions and Pass4sure dumps

    NEW YORK--(BUSINESS WIRE)--Priority Income Fund, Inc. ("Priority Income Fund" or the "Fund") is pleased to promulgate the declaration of distributions on shares of the Fund’s 6.375% progression A Term Preferred Stock due 2025 and 6.25% progression B Term Preferred Shares due 2023.

    The Fund has declared a distribution of $0.39844 per partake on its 6.375% progression A Term Preferred Stock due 2025 and a distribution of $0.29080 per partake 6.25% progression B Term Preferred Shares due 2023.

          Ex-Dividend Date     Record Date     Payable Date     Amount per Share 6.375% progression A Term Preferred Stock due 2025     December 13, 2018     December 15, 2018     December 31, 2018     $0.39844 6.25% progression B Term Preferred Shares due 2023     December 13, 2018     December 15, 2018     December 31, 2018     $0.29080

    The distributions on the 6.375% progression A Term Preferred Stock due 2025 reflect an annual distribution rate of 6.375% of the $25 liquidation preference per partake and 6.25% progression B Term Preferred Shares due 2023 reflect an annual distribution rate of 6.25% of the $25 liquidation preference per share.

    About Priority Income Fund

    Priority Income Fund, Inc., is a registered closed-end fund that was created to acquire and grow an investment portfolio primarily consisting of senior secured loans or pools of senior secured loans known as collateralized loan obligations ("CLOs"). Such loans will generally beget a floating interest rate and embrace a first lien on the assets of the respective borrowers, which typically are private and public companies based in the United States. For more information, visit priority-incomefund.com.

    About Prospect Capital Management L.P.

    Headquartered in original York City, Prospect is an SEC-registered investment adviser that, along with its predecessors and affiliates, has a more than 25-year history of investing in and managing high-yielding debt and equity investments using both private partnerships and publicly traded closed-end structures. Prospect and its affiliates employ a team of approximately 100 professionals who focus on credit-oriented investments yielding attractive current income. Prospect has $6.6 billion of assets under management as of September 30, 2018. For more information, summon 212.448.0702 or visit prospectcapitalmanagement.com.

    About Destra Capital

    Destra Capital connects financial advisors and their clients with innovative investment strategies, in uniquely positioned products from experienced asset managers. Destra takes the long view, setting goals to rise above fleeting market statistics toward the chance for long-term returns. Destra Capital Investments LLC is a member FINRA/SIPC.

    Additional Information

    Past performance is not indicative of future performance. Our distributions may exceed their earnings, and therefore, portions of the distributions that they build may subsist a recrudesce of the money that you originally invested and delineate a recrudesce of capital to you for tax purposes. Such a recrudesce of capital is not immediately taxable, but reduces your tax basis in their shares, which may result in higher taxes for you even if your shares are sold at a charge below your original investment.

    Investors should consider the investment objective and policies, risk considerations, charges and ongoing expenses of an investment carefully before investing. The prospectus and summary prospectus contains this and other information germane to an investment in the fund. tickle read the prospectus or summary prospectus carefully before you invest or transmit money. To obtain a prospectus, tickle contact your investment representative or Destra Capital Investments LLC at 877.855.3434.

    Forward-Looking Statements

    This press release may contain sure forward-looking statements within the acceptation of the Private Securities Litigation Reform Act of 1995, including statements regarding the future performance of Priority Income Fund, Inc. Words such as "believes," "expects," "projects," and "future" or similar expressions are intended to identify forward-looking statements. Any such statements, other than statements of historical fact, are highly likely to subsist affected by unknowable future events and conditions, including elements of the future that are or are not under the control of Priority Income Fund, Inc. and that Priority Income Fund, Inc. may or may not beget considered; accordingly, such statements cannot subsist guarantees or assurances of any aspect of future performance. Actual developments and results are highly likely to vary materially from any forward-looking statements. Such statements discourse only as of the time when made, and Priority Income Fund, Inc. undertakes no duty to publicly update or revise any forward-looking statements, whether as a result of original information, future events or otherwise.



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    mySQL [4 Certification Exam(s) ]
    NBSTSA [1 Certification Exam(s) ]
    NCEES [2 Certification Exam(s) ]
    NCIDQ [1 Certification Exam(s) ]
    NCLEX [2 Certification Exam(s) ]
    Network-General [12 Certification Exam(s) ]
    NetworkAppliance [36 Certification Exam(s) ]
    NI [1 Certification Exam(s) ]
    NIELIT [1 Certification Exam(s) ]
    Nokia [6 Certification Exam(s) ]
    Nortel [130 Certification Exam(s) ]
    Novell [37 Certification Exam(s) ]
    OMG [10 Certification Exam(s) ]
    Oracle [269 Certification Exam(s) ]
    P&C [2 Certification Exam(s) ]
    Palo-Alto [4 Certification Exam(s) ]
    PARCC [1 Certification Exam(s) ]
    PayPal [1 Certification Exam(s) ]
    Pegasystems [11 Certification Exam(s) ]
    PEOPLECERT [4 Certification Exam(s) ]
    PMI [15 Certification Exam(s) ]
    Polycom [2 Certification Exam(s) ]
    PostgreSQL-CE [1 Certification Exam(s) ]
    Prince2 [6 Certification Exam(s) ]
    PRMIA [1 Certification Exam(s) ]
    PsychCorp [1 Certification Exam(s) ]
    PTCB [2 Certification Exam(s) ]
    QAI [1 Certification Exam(s) ]
    QlikView [1 Certification Exam(s) ]
    Quality-Assurance [7 Certification Exam(s) ]
    RACC [1 Certification Exam(s) ]
    Real-Estate [1 Certification Exam(s) ]
    RedHat [8 Certification Exam(s) ]
    RES [5 Certification Exam(s) ]
    Riverbed [8 Certification Exam(s) ]
    RSA [15 Certification Exam(s) ]
    Sair [8 Certification Exam(s) ]
    Salesforce [5 Certification Exam(s) ]
    SANS [1 Certification Exam(s) ]
    SAP [98 Certification Exam(s) ]
    SASInstitute [15 Certification Exam(s) ]
    SAT [1 Certification Exam(s) ]
    SCO [10 Certification Exam(s) ]
    SCP [6 Certification Exam(s) ]
    SDI [3 Certification Exam(s) ]
    See-Beyond [1 Certification Exam(s) ]
    Siemens [1 Certification Exam(s) ]
    Snia [7 Certification Exam(s) ]
    SOA [15 Certification Exam(s) ]
    Social-Work-Board [4 Certification Exam(s) ]
    SpringSource [1 Certification Exam(s) ]
    SUN [63 Certification Exam(s) ]
    SUSE [1 Certification Exam(s) ]
    Sybase [17 Certification Exam(s) ]
    Symantec [134 Certification Exam(s) ]
    Teacher-Certification [4 Certification Exam(s) ]
    The-Open-Group [8 Certification Exam(s) ]
    TIA [3 Certification Exam(s) ]
    Tibco [18 Certification Exam(s) ]
    Trainers [3 Certification Exam(s) ]
    Trend [1 Certification Exam(s) ]
    TruSecure [1 Certification Exam(s) ]
    USMLE [1 Certification Exam(s) ]
    VCE [6 Certification Exam(s) ]
    Veeam [2 Certification Exam(s) ]
    Veritas [33 Certification Exam(s) ]
    Vmware [58 Certification Exam(s) ]
    Wonderlic [2 Certification Exam(s) ]
    Worldatwork [2 Certification Exam(s) ]
    XML-Master [3 Certification Exam(s) ]
    Zend [6 Certification Exam(s) ]





    References :


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    Dropmark-Text : http://killexams.dropmark.com/367904/12955637
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