Regulatory lawyer Bill Singer has analyzed and posted the latest crop of FINRA disciplinary cases
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From at least September 2005, BRG and its subsidiary, BCM failed to establish, maintain and enforce policies and procedures reasonably designed, taking into account the nature of their respective and interconnected businesses, to prevent the misuse of material, nonpublic information. For 2005, BCM also failed to conduct an annual review of the adequacy of its compliance policies and procedures and the effectiveness of their implementation, as required by the Advisers Act.
In anticipation of the institution of proceedings, Respondents submitted Offers of Settlement (the "Offers")(without admitting or denying the findings) which the SEC accepted. Respondents consented to the entry of this Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Sections 15(b) and 21C of the Securities Exchange Act of 1934 and Sections 203(e), 203(f) and 203(k) of the Investment Advisers Act of 1940, Making Findings and Imposing Remedial Sanctions and a Cease-and-Desist Order ("Order").In the Matter of THE BUCKINGHAM RESEARCH GROUP, INC., BUCKINGHAM CAPITAL MANAGEMENT, INC., and LLOYD R. KARP, Respondents (Order Instituting Administrative And Cease-Anddesist Proceedings Pursuant To Sections 15(B) And 21c Of The Securities Exchange Act Of 1934 And Sections 203(E), 203(F) And 203(K) Of The Investment Advisers Act Of 1940, Making Findings And Imposing Remedial Sanctions And A Cease-And-Desist Order, Investment Advisers Act Of 1940 Release No. 3109 / Administrative Proceeding File No. 3-14125, November 17, 2010).