Placee Independence – Key Takeaways from the Latest SFC Disciplinary Actions
Client Memorandum

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The Securities and Futures Commission (SFC) announced on May 21, 2014 and December 10, 2014 that it had disciplined a Type 6 corporate finance adviser (A), its affiliated Type 1 broker entity (B) and a former responsible officer of the broker (C) for their failures to ensure the independence of all placees in an initial public offering (IPO) in 2009.  Each of A and B was publicly reprimanded and fined $12.5 million, while C has been suspended for eight months.

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