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Unformatted text preview: reconciliation
– No officer loans
– File any trading information within two business
– Code of ethics
– Disclose off-balance sheet financing
– Disclose any non-GAAP financial measures Corporate Provisions
Audit Committee of Board
– Responsible for oversight of external audit
– Be independent of the firm
– Set up whistle-blowing provisions
– One must be financial expert Penalties
If alter, destroy, cover-up or falsify documents with
objective to hinder investigation – fines and up to
Give back to firms any bonuses, incentive
compensation or equity based compensation
earned within 12 months
False certification - $1m and up to 10 yrs.
Willful false cert. - $5 m and up to 20 yrs.
Company can hold up any payments to officers Penalties
– Temporary suspension from industry
– Temporary or permanent revocation of license
– Can’t go to another firm if suspended or license
– Fines of up to $100,000 personal for each
violation, firm up to $2 m
– If intentional...
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- Winter '12