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Recent Enforcement Actions Reinforce the Need for a Dynamic Compliance Program and Reflect a Growing Impatience With Inadequate Supervisory Programs

Two recent enforcement actions, one by the Securities and Exchange Commission ("Commission") against Consulting Services Group, LLC (“CSG”), an investment adviser, and one by the Financial Industry Regulatory Authority (“FINRA”) against Franklin Ross, Inc., a broker-dealer, serve as a reminder that firms must implement compliance programs that are specifically tailored to the firm’s business. These enforcement proceedings also highlight the obligation of firms actually to comply with and enforce those procedures.
 
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