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Gallagher Uncorks on SEC Action Against CCOs

Matt Kelly | June 18, 2015

Dan Gallagher, often a contrarian voice of the Securities and Exchange Commission, spoke up again this week to denounce recent SEC enforcement actions against compliance officers at investment advisory firms.

Gallagher, a Republican appointee to the SEC and set to leave the Commission later this summer, took the unusual move Thursday of publishing his own statement about two enforcement actions that he opposed: the first against the chief compliance officer of Blackrock Advisors, doled out in April; the second against the CCO of SFX Financial Advisory, handed down on June 15. “These recent actions fly in the face of my admonition,” he said, “and I feel compelled to explain my rationale for dissenting.”

And explain he did, in an 893-word fusillade aimed squarely at how the SEC applies Rule 206(4)-7. That rule dictates the policies and procedures that registered investment advisers...

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