 How to effectively implement operational separation in an integrated financial services enterpriseC Dirk Peterson Journal of Financial Compliance, 2019, vol. 2, issue 4, 371-379 Abstract: The US federal securities laws require broker-dealers and investment advisers to protect the flow of material, non-public information (MNPI) to prevent violations of the securities laws. Barriers are an integral part of the compliance programme at large diversified financial organisations. In addition to addressing issues of insider trading or front-running, each a form of fraud prohibited by the anti-fraud provisions of the US federal securities laws, information barriers also perform operational functions to separate affiliates and business units as a demonstration of independent uncoordinated investment control or power. Separation demonstrates that each affiliate or business unit operates independently to permit disaggregating investment holdings or transactions that might otherwise be prohibited. This paper addresses certain of the operational benefits of information barriers outside of their customary uses for the protection of material, MNPI. Keywords: information barriers; material; non-public information; Securities and Exchange Commission (SEC) regulation (search for similar items in EconPapers) Downloads: (external link) Related works: Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text Persistent link: https://EconPapers.repec.org/RePEc:aza:jfc000:y:2019:v:2:i:4:p:371-379 Access Statistics for this article More articles in Journal of Financial Compliance from Henry Stewart Publications |
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