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Topic: Errors

Self-Report or Not: Consider What’s at Stake

March 30, 2018
The SEC’s recent share class initiative – in which the agency promises not to charge civil money penalties to advisers that voluntarily report that they placed clients in certain share classes when less expensive classes were available – has cast a spotlight on the question of whether self-reporting is a good idea.

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Don’t Err When Handling Errors: Documentation and Internal Reporting are Key

February 21, 2014
Despite your best efforts, some errors will always get through. How a firm handles them is critical.

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Coding Error Settlement: Compliance Requires More Than a Narrow Reading of Policies

January 31, 2014
Don’t interpret your compliance polices so narrowly that you fail to do what’s right. You may just end up fooling yourself – and leaving your firm liable to SEC action.

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