10 Principles For Enhancing IT Control Programs

Law360 (June 19, 2007, 12:00 AM EDT) -- On May 9, 2007, the Securities Exchange Commission brought an administrative proceeding against a large investment bank alleging that the firm embedded undisclosed mark-ups and mark-downs in certain OTC executions and delayed execution of other orders, thereby not providing best execution to its retail customers(In re Morgan Stanley & Co., Securities Exchange Act Release No. 55726 [May 9, 2007]). The SEC alleged that the firm was reckless in improperly programming its automated OTC marketmaker system, which caused the errors.

Without admitting or denying the allegations, the...
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