More On Legal & Compliancefrom The Advisor's Professional Library
- Client Commission Practices and Soft Dollars RIAs should always evaluate whether the products and services they receive from broker-dealers are appropriate. The SEC suggested that an RIAs failure to stay within the scope of the Section 28(e) safe harbor may violate the advisors fiduciary duty to clients, so RIAs must evaluate their soft dollar relationships on a regular basis to ensure they are disclosed properly and that they do not negatively impact the best execution of clients transactions.
- The Need for Thorough and Effective Policies and Procedures Whethere an advisor is SEC or state-registered, RIAs must revise their policies and procedures to address significant compliance problems occurring during the year, changes in business arrangements, and regulatory developments.
SEC Chairwoman Elisse Walter appointed Geoffrey F. Aronow on Monday as the agency’s general counsel, replacing Mark Cahn, who left the agency last week. Aronow will begin his new role later this month.
Aronow comes to the SEC from the law firm of Bingham McCutchen LLP, where he is a partner in the Washington office. Aronow served as head of enforcement for the Commodity Futures Trading Commission (CFTC) from September 1995 to June 1999.
As the SEC’s chief legal officer, Aronow will lead the Office of the General Counsel in advising the commission on issues ranging from enforcement actions, rulemakings, and legal proceedings in federal courts throughout the country.
“Geoff brings the ideal combination of practical knowledge, expertise, and common sense that is so critical to addressing the often nuanced and difficult issues that come before the commission,” said Walter, in a statement. “Geoff is a faithful steward of the securities laws with a comprehensive understanding of law enforcement who shares our commitment to excellence and passion for investor protection.”
Aronow said in the same statement that, “I’m truly honored to re-enter public service as the general counsel at an agency with such a storied history and critical mission of investor protection and effective market oversight. It is humbling to lead a dedicated staff of so many talented and distinguished lawyers in the Office of the General Counsel, and I look forward to working with them closely as we provide the wisest advice possible to Chairman Walter, the other commissioners, and agency staff.”
Aronow, 57, has worked at Bingham McCutchen since August 2008 and has advised clients on matters before the SEC, CFTC and other federal agencies as well as in litigation in federal courts and on legislative initiatives before Congress. His other legal experience includes two stints as a partner at Arnold & Porter LLP (1988 to 1995 and 1999 to 2004). He worked at Heller Ehrman LLP from 2004 to 2008.
Aronow is a former member of the National Adjudicatory Council, NASD Regulation. He also served on the board of directors for the National Capital Area Chapter of the American Civil Liberties Union.
Since 2010, Aronow has served as an adjunct professor at George Washington University Law School, where he co-teaches a seminar on futures and derivatives law. He previously served as an adjunct professor for two years at Catholic University’s Columbus School of Law. Mr. Aronow earned his J.D. from Yale Law School and earned his B.A. (summa cum laude and Phi Beta Kappa) from Yale College.