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This
document
is
subject
to
the provisions
orthe
Privacy
Act
of
1974,
andmay
require
redaction before
disclosure
to
tbird
parties_
No
redaction
hasbeen performed
by
the
Office
or
Inspector General.
Recipients
of
this
report
shouldnot disseminate
or
copy
it
wilhout
(he
(nspectorGeneral's approval.
Report
of
Investigation
Case
No. OIG-481
Table
of
Contents
Introduction
and Summaryof
Investigative Findings
and
Recommendations
.
.
L
Introduction
II.
summary
of
Investigative Findings and Recommendations
Scope
of
Investi.gation
Relevant
Commission
and
Government
Regulations
and
Policies
A.
.
SEC
Employees
to
Maintain Unusually High Standards
of
Conduct
B.
Duty to Use Goverrunent Property for Authorized Purposes
Tbe
Commission'S
Table
of
Penalties
and
Relevaot
Case Law
Background
and
Investigative
Findings
L Results
of
the Investigation
n.
Rule 5
of
the Commission's Conduct Regulation
Ill.
A.
The Mission
of
he Agency .
c.
Restrictions
orfSEC
Employee Trading
in
SecuritiesDesigned to Ensure Public Confidence
&
Prev~nt
Real
or
Apparent Conflicts
of
InterestStrict Interpretation
of
Rule 5The Rule 5 "Compliance System"
1
2
45
5.
6
7
8
8
99
9
1I
II
~ . - ' ! -
 
Tbis
document
is
subject
to the
provisionsoftbe Privacy
Act
of
1974,
and
lI13y
require
redaction
hd·,\.
disclosure to
third
parties. No redaction bas been
performed
by
the
Office
of
Inspector
General.
I~,"
i~'i
•.
'"
of
this
report
should
no'
disseminate
or
copy
it
without
tbe Inspector
General's
:approval.
B.
c.
Report
of
Investigation
Cas,e No. OIG-481
Table
of
Contents,
Con't.
Conduct Regulation Securities Transaction System
("CRST")
Financial Disclosure Reports
It
12I.
SEC
Form
68-1
12
2.
aGE
Form 450 Confidential Financial
DisclosureReport
13
Employees Cannot Clear Securities Transactions
on
Other
SEC
Data Systems
Qr
Share Information about
Why Certain
Transactions are Restricted
14
IV. . Training
on
Rule 5 Requirements and Confidentiality
ofNonPublic
Information
14'
A.
Rule 5
14B.
Confidentiality
of
Enforcement's' Investigations
15
Investigative Findings
I.
Enforcement Attorneys Fail to
Comply
with
~ule
5
1.6
A. Long-Time Enforcement AttorneYs
Share
Friendships
16
B.
Their
Securities Trading and
Stock
Portfolios
17
C.
No Tracking Systems to
Ensure Compliance with
Rule
518
'D.
Failures to Report
SecuritiesTransactions
19
1.
Failure to Consistently
File
SEC
Form
681
19
2
of 00

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