More On Legal & Compliancefrom The Advisor's Professional Library
- Code of Ethics Rule The Code of Ethics Rule, found in Rule 204A-1, uses severe consequences for violation to help ensure investment advisors will do the right thing.
- Client Communication and Miscommunication RIA policies and procedures must specify what type of communications should be retained. The safest course of action is for RIAs to retain all communicationsto clients, from clients, and about client accounts. To comply with fiduciary obligations, communications must be thorough and not mislead.
During her first day as the new chairman of the SEC, Elisse Walter appointed two acting directors, one to the Division of Corporation Finance and the other to Trading and Markets.
Lona Nallengara will be the acting director of Corporation Finance, replacing Meredith Cross when she leaves the SEC to return to the private sector at year-end. John Ramsay will become acting director of Trading and Markets, replacing Robert Cook, who announced that he plans to step down after a short transition period.
Both Cross and Cook announced their planned departures the week of Dec. 3.
Nallengara has served as deputy director for legal and regulatory policy of the division since March 2011 and has been responsible for overseeing the Division’s offices of Chief Counsel, Enforcement Liaison, International Corporate Finance, Mergers and Acquisitions and Small Business Policy.
Nallengara is also credited with leading a series of complex rulemakings required by the Dodd-Frank Act and the division’s implementation of the Jumpstart Our Business Startups Act.
“Lona understands that our financial system is premised on investors getting the information they need to make smart decisions and on businesses having access to new capital,” Walter said in a statement. “Lona has extensive experience working within the agency and with companies seeking to raise capital. He appreciates the impact that our rules have not only on the lives of everyday investors, but also on the financial system as a whole.”
Nallengara joined the SEC from Shearman & Sterling LLP in New York, where he was a partner in the Capital Markets practice group and advised public companies and financial institutions in a wide range of capital raising activities and on corporate governance, public reporting and mergers and acquisitions matters. He earned his law degree from Osgoode Hall Law School in Toronto and his undergraduate degree in Political Science from the University of Western Ontario in London, Canada.
Ramsay has served as a deputy director for trading and markets and is responsible for broker-dealer financial responsibility, risk oversight, and clearance and settlement functions. He has played a key role in the advancement of rules mandated by the Dodd-Frank Act.
“John has a wealth of experience to draw upon and a firm grasp of the intricacies of issues,” Walter said in the statement. “He is well-positioned to oversee the Division as we continue to further bolster the markets and ensure they operate fairly and efficiently.”
Ramsay previously worked at the SEC from 1989 to 1994 in various posts including as counsel to then-Commissioner Mary Schapiro, who departed the agency on Friday. He also has held other key regulatory policy positions at the Commodity Futures Trading Commission and the National Association of Securities Dealers (now the Financial Industry Regulatory Authority). In the private sector, Ramsay worked as a partner at the law firm of Morgan Lewis and Bockius, senior vice president of the Bond Market Association (now the Securities Industry and Financial Markets Association), and managing director and deputy general counsel at Citigroup Global Markets.
Ramsay received his J.D. from the University of Michigan in 1984 and graduated summa cum laude from the University of Texas at Austin in 1981, where he was elected to Phi Beta Kappa.