One of any firm’s most valuable assets is its reputation.  Fostering a culture of ethics and compliance is critical to protecting that asset, your firm, and its people.  Mr. Wasserman has served for more than a decade as a Senior Fellow from Practice at the Regulatory Compliance Association and regularly speaks and writes on ethics and compliance topics, including navigating compliance black swans, the difference between ethics and compliance, CEO and Chief Compliance Officer liability, insider trading in the US and globally, the use of 10b5-1 plans, creating safe and effective expert network programs, avoiding failures to supervise, and SEC and SRO enforcement initiatives.   

August Way is pleased to assist financial institutions in promoting a culture of compliance and mitigating regulatory risks — working with organizations on their policies and procedures, providing regulatory counsel and real time advice, and assisting firms with their periodic regulatory examinations.    

Policies and Procedures

Mr. Wasserman has extensive experience crafting, assessing, and updating policies and procedures to assure that they are reasonably designed to protect the institution and comply with the law.  At the New York Stock Exchange, Mr. Wasserman drafted the Market Regulation Department’s Ethics Policy and Surveillance, Investigation, and Enforcement Policies and Procedures.  He also oversaw hundreds of investigations into financial firms’ supervisory practices, policies and procedures – focusing on such topics as the Market Access Rule, preventing market manipulation, market making responsibilities, information barriers, best execution, wash sales, net capital requirements, margin requirements, ADRs, anticipatory hedging, Reg. SHO, and equities and options order handling.  In private practice, Mr. Wasserman advised funds, banks, and other institutions on policies covering insider trading, expert networks, 10b5-1 plans, gifts and entertainment, and conflicts of interest (among other topics).

Mr. Wasserman recognizes that a firm’s policies not only need to be easy to understand, but that having the most comprehensive procedures on paper means nothing if they cannot realistically be followed.  August Way is well versed in assisting firms to help make certain their policies and procedures meet both their regulatory and business needs.         

Regulatory Counsel & Real Time Advice

Even with the best policies, practices and procedures, risk and compliance issues will arise that require expert and thoughtful answers.  Some of these questions, like how to structure a new regulatory compliant financial product, may call for research and strategic thinking.  Others, like whether or not a specific trade raises regulatory risks, will require answers in real time.  In either case, with 25 years of experience covering nearly every major regulatory investigation facing the financial services industry, Mr. Wasserman is positioned to provide the answers you need so that your firm can achieve its business goals properly and consistent with the law and rules.    

Examinations

Nearly all financial firms are subject to periodic examinations by their regulators – whether the SEC, FINRA, the Federal Reserve, the OCC, or others.  As Head of Enforcement at the NYSE, Mr. Wasserman coordinated closely with numerous SEC and FINRA examination teams and helped oversee FINRA’s examination program on behalf of NYSE and evaluated and approved hundreds of exam recommendations.  Additionally, Mr. Wasserman has extensive experience in representing a variety of financial institutions in responding to regulatory examinations.  August Way will work with you and your regulators to help assure that your firm’s examination goes as smoothly, with as little interruption to your business, as possible.

Please contact August Way for a complimentary consultation on how Mr. Wasserman can help your organization foster and maintain a culture of compliance.