The SEC said that, as part of its agreement with Lockwood, the firm has initiated changes to its policies and procedures designed to ensure transparency in its wrap program. The changes include making inquiries with prospective wrap program portfolio managers about their trading away histories; requesting that portfolio managers submit information about how often and at what volume they have traded away; and instituting measures to make sure the trading away information is disclosed to clients and their RIAs.
When contacted for a comment, Pershing spokesperson Sanuber Grohé responded via e-mail, "It is our firm policy not to comment on regulatory matters."