“Bad Actor” Waivers Getting Harder to Get

After giving an investment adviser that failed to get clients’ consents for 21,000 trades a “bad boy” waiver, the Securities and Exchange Commission is now considering punishing JP Morgan.

The Wall Street Journal reports that the Commission is thinking about restricting JPM from engaging in private placements for its clients because it didn’t make proper disclosures when touting its own investment products to clients over those offered by its competitors.

Could be that the recent public criticism, some from the Commissioners themselves, has caused the SEC to begin to crack down on the large miscreants.

SEC No-Action Letter – Matter of National Asset Management. Inc. CSF-3940)  http://www.sec.gov/divisions/corpfin/cf-noaction/2015/nam-102615-506d.pdf

WSJ: http://www.wsj.com/articles/sec-takes-tougher-stance-on-enforcement-in-j-p-morgan-case-1445986962

About JeffKoeppel

I am a corporate/securities attorney in the Washington, DC area. Prior to joining the firm, I was a Senior Attorney Advisor in the Division of Corporation Finance at the U.S. Securities and Exchange Commission. I am a member of the Bars of the States of Maryland, New York and the District of Columbia. You can also follow this blog on LinkedIn at: http://www.linkedin.com/pub/jeffrey-a-koeppel/0/63/5a9
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