The latest wrinkle in the VelocityShares Daily Inverse VIX Short-Term exchange traded note's fall from grace concerns its issuer, Credit Suisse, and regulatory filings that several firm executives purportedly skipped out on completing mandatory training programs by having their secretaries complete the online programs and modules instead.
For example, FINRA disciplined Managing Director and Head of Global Asset Finance executive Jay Kim for providing administrative assistants with his username and password to the online eLearning website containing the mandatory training materials and modules, allowing these assistants to complete at least five eLearning modules in Kim's name and in contravention of industry rules.
The findings state that Kim's assistants improperly completed eLearning modules related to unauthorized trading awareness, money laundering, corruption, and global records management, using Kim's credentials, thus giving supervisor Kim credit for completing a training activity that a subordinate had actually completed.
Credit Suisse was previously sanctioned for supervisory failures and violations related to the content of several of the eLearning modules referred to in the Kim disciplinary action.