• Not Throwing Away Your Shot: Relying on Compliance Consultants to Defend Regulatory Actions
  • February 24, 2017 | Authors: Brian L. Rubin; Rebekah R. Runyon
  • Law Firms: Eversheds Sutherland (US) LLP - Washington Office; Eversheds Sutherland (US) LLP - Atlanta Office
  • NSCP Currents

    Full article

    You are a CCO who is responsible for completing and filing Form ADV. You hire a compliance consultant to advise you on what information to include. You act in accordance with that advice, but you later find out that the SEC has instituted a proceeding against you and the firm due to the firm’s inadequate disclosures. So, what now?

    In their article for NSCP Currents, Eversheds Sutherland (US) attorneys Brian Rubin and Rebekah Runyon discuss:
    • How do you defend yourself and the firm in this proceeding?
    • Is reliance on compliance consultants an available defense?
    • Will that succeed?
    • Who lives, who dies, and who tells your story (as Alexander Hamilton might say)?