Series with an Anonymous African-American politician in front of United States flag.  A variety of concepts and props, including healthcare, education, wealth and poverty.

Pay to Play Rule In Effect on July 31

The Securities and Exchange Commission announced the compliance date for the ban on third-party solicitation pursuant to the Pay-to-Play rule: July 31, 2015. Rule 206(4)-5 prohibits an investment adviser from providing compensated services to a government entity, following a political contribution to certain officials of that entity. Rule 206(4)-5 became effective on September 13, 2010 […]

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Compliance Bricks and Mortar for July 24

These are some of the compliance-related stories that recently caught my attention in between bike rides.(It’s not too late to support my Pan-Mass Challenge ride to support cancer research.) SEC hires new private funds specialist by Katherine Bucaccio in Private Funds Manangement Jennifer Duggins will join the commission later this month to co-head OCIE’s Private […]

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SEC Meet and Greet – Part 2

Last week I was able to share with you the introductory letter from a firm that recently registered with the Securities and Exchange Commission and quickly received a meet and greet request. That same reader was nice enough to share his experience with me and the readers of Compliance Building. The SEC had a four […]

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Compliance Bricks and Mortar for July 17

These are some of the compliance related stories that recently caught my attention. Deflategate (Part Two): My texts runneth over by Joshua C. Garbarino in The FCPA Blog The spontaneous nature of texts, often with photos, and sending them before anyone thinks about the consequences, means the texts can be a very revealing source of […]

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BE-10 Survey Requirements: What Private Equity Funds Need to Know

Under the International Investment and Trade in Services Survey Act of 1977, the U.S. Bureau of Economic Analysis in the Department of Commerce conducts a “benchmark survey” of U.S. direct investment abroad every five years. U.S.-based companies with ownership of “foreign affiliates” are required by law to participate in the survey by completing and submitting a […]

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SEC Meet and Greet

The Securities and Exchange Commission tackled a large group of new advisers, Post-Dodd-Frank, with the Presence Exam initiative. Then tackled a backlog of exams with the never-before examined initiative. The SEC stated that it wanted to start reaching out to advisers soon after they register to get on top of things from the onset. A […]

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Compliance, Cycling and the Tour de France

For me, July starts with the red, white and blue, then quickly turns to yellow. The yellow jersey worn by the overall leader of the Tour de France.   I’ve been a big fan of the Tour de France for the past decade and a half. I admit that it was the success of Lance […]

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A History of the World in Sixteen Shipwrecks

Weekend Reading: A History of the World in Sixteen Shipwrecks

Shipwrecks are tragic, but have been a part of human history since we started making ships. There are an estimated three million ships sitting on the bottom of the oceans, seas, lakes, and rivers of the world. Of that staggering number, Stewart Gordon picked sixteen to tell the story of human history. A History of […]

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ReTIRE Initiative

The SEC said it would focus on matters relating to retail investors saving for retirement and the SEC followed through with the new exam focus: the ReTIRE Initiative. We’ve seen this coming. The National Exam 2015 priorities list stated that OCIE will focus on how retail investors at or nearing retirement are being served by […]

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Compliance Bricks and Mortar for the July Fourth Weekend

These are some of the compliance-related stories I set aside to read this holiday weekend. What Do Rating Agencies Think about “Too-Big-to-Fail” Since Dodd-Frank? by Gara Afonso and João Santos in Liberty Street Economics Is it possible that, while S&P still expects support for some BHCs, the perceived strength of support has decreased and is […]

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