To Disclose or Not To Disclose: That is the Question

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2 Responses

  1. Kevin L. Warmack says:

    The decision whether or not to voluntarily disclose a violation also extends to issues involving regulations. For instance, a number of broker-dealer firms are hesitant to report a regulatory violation that may have happened due to a clerical error or something small because they are afraid of the “Wrath of FINRA!!” As with the DOJ, the question becomes how much of a fine is the firm and/or the supervisor going to have to pay as well as will the supervisor have to take some time out.

    As you clearly stated in your conclusion, there needs to be standards and policies for voluntary disclosures with the DOJ, SEC and any other regulatory agency otherwise it may continue to be a continued done in secret movement.

  1. February 10, 2012

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