TAILIEUCHUNG - Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC

The analysis of the factor models is interesting in its own right. Surpris- ingly,much of the literature on international stock return comovement imposes strong restrictions of constant, unit betas with respect to a large number of country and industry factors, as in the Heston and Rouwenhorst (1994) model. We contrast the predictions of these models for stock return comovements with our risk-based models. While f lexibility in the modeling of betas is essential in a framework where the degree of market integration is changing over time, thismay not suffice to capture the underlying structural changes in the various markets. Therefore, in addition to standard models of risk like. | . Securities and Exchange Commission a fg Office of Inspector General Office of Audits Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities LLC OFFICE OF NSPECTOR GENERAL UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON . 20549 MEMORANDUM September 29 2009 To Mary L. Schapiro Chairman John H. Walsh Acting Director Office of Compliance Inspections and Examinations From H. David Kotz Inspector General Office of Inspector General OIG Subject Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities LLC Report No. 468 This memorandum transmits the . Securities and Exchange Commission OIG s final report detailing the results of the review conducted by FTI Consulting Inc. of the Office of Compliance Inspections and Examinations OCIE examinations of Bernard L. Madoff and Bernard L. Madoff Investment Securities LLC. The review was conducted as part of the OIG s continuous efforts to assess management of the Commission s programs and operations. OCIE concurred with the report s 37 recommendations. Based on the written comments that were received and our assessment of the comments we revised the report accordingly. Within the next 45 days please provide OIG with a written corrective action plan that is designed to address the agreed upon recommendations. The corrective action plan should include information such as the responsible official point of contact time frames for completing the required actions milestone dates identifying how you will address the recommendations cited in this report etc. Should you have any questions regarding this report please do not hesitate to contact me. We appreciate the courtesy and cooperation that you and your staff extended to our contractor. Attachment cc Kayla J. Gillan Deputy Chief of staff Office of the Chairman Diego Ruiz Executive Director Office of the Executive Director Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities LLC

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• Induced Abortion