On July 11, 2011, the SEC announced that it had settled charges against Janney Montgomery Scott LLC, a broker-dealer, for failure to establish and enforce policies and procedures required by law to prevent the misuse of material, non-public information. According to the SEC, from January 2005 to July 2009, Janney‟s policies and procedures for its equity sales, trading, syndicate and research departments were deficient. The SEC found that in certain circumstances the policies were either incomplete, not enforced or not followed as written. Specifically, the SEC found that Janney failed to (1) adequately monitor trading in the securities of companies that were clients of its investment banking division, (2) maintain an adequate email „firewall‟ between its investment banking and research staff, (3) enforce procedures regarding meetings between investment banking and research staff, (4) require investment bankers to pre-clear personal trades, and (5) enforce policies regarding brokerage accounts at other firms. Janney agreed to be censured and to pay an $850,000 penalty.