The Definitioft of 'Supervisor': Urban Muddies The Water

摘要

The Commission's definition of a "supervisor" in the Gutfruend Section 21(a) report suggests that legal and compliance officers are potentially liable for supervisory failure under Section 15(b)(4)(E) of the Exchange Act. The ALJ in Urban applied the Gutfreund definition and found that General Counsel Urban was a statutory supervisor of one of his firm's 275 brokers.