Compliance


The SEC proposes two rules that would allow it to supervise broker-dealers and their affiliates on a consolidated basis ( www.sec.gov/news/press/2003-134.htm ). One proposal would create an alternative method for computing certain net capital charges for broker-dealers that are part of a holding company that manages risks—and consents to SEC supervision—on a groupwide basis. The other proposed rule would implement section 17(i) of the Securities Exchange Act of 1934, which created a new structure for consolidated supervision of broker-dealers’ holding companies and their affiliates. Such SEC supervision would include recordkeeping, reporting and examination requirements. This proposal also would adjust the audit requirements for over-the-counter derivatives dealers to allow accountants to use agreed-upon procedures when conducting audits of risk management control systems. Comments are due by February 4.

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Deflecting clients’ requests for defense and indemnity

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