More On Legal & Compliancefrom The Advisor's Professional Library
- Privacy Policies and Rules Whether an RIA is SEC or state-registered, the firm must have policies and procedures in effect to protect clients privacy. Policies and procedures should explicitly require an RIA to send out its privacy notice each year.
- Updating Form ADV and Form U4 When it comes to disclosure on Form ADV, RIAs should assume information would be material to investors. When in doubt, RIAs should disclose information rather than arguing later with securities regulators that it was not material.
The chairman of the House Financial Services Oversight and Investigations Subcommittee told the New York Federal Reserve Bank Monday that he wants more information about the handling of banks’ alleged “manipulation and suppression” of the London Interbank Offered Rate (LIBOR).
In a Monday letter to the Fed branch's president, William Dudley, the subcommittee chairman, Rep. Randy Neugebauer, R-Texas, said that the previous information Dudley had presented revealed that the New York Fed knew that certain financial institutions were “not posting honest LIBOR rates.” He said the documents showed that the Fed “worked to identify flaws in the way LIBOR was set and subsequently made recommendations for enhancing the credibility of the rate to the Bank of England.”
However, Neugebauer told Dudley that “what is less clear” was how the Fed “dealt with admissions of market manipulation by LIBOR-contributing banks.”
Said Neugebauer to Dudley: “As you know, the role of the government is to ensure that our markets are run with the highest standards of honesty, integrity and transparency. Therefore, any admission of market manipulation—regardless of degree—should be swiftly and vigorously investigated.”
Neugebauer told Dudley that “there are many outstanding questions” regarding the NY Fed’s role in the LIBOR scandal. The letter asked that by Sept. 1, the New York Fed provide documents on all communications since August 2007 among its employees and with U.S. and British government officials, as well as with regulators in both countries, the British Bankers Association and employees of LIBOR-contributing banks, on the setting of LIBOR.