New Year’s Eve is generally a time to reflect on the past and look forward to the future. For many it also involves an excessive amount of alcohol, an expensive dinner in a crowded restaurant, or a long wait for Chinese food delivery. I’m sure there is a compliance story in there somewhere. But I’m […]
Nassim N. Taleb, Daniel G. Goldstein, and Mark W. Spitznagel discuss risk management and short comings in approaches in the October 2009 issue of the Harvard Business Review (subscription required). They offer up six mistakes in the way we think about risk: 1. We think we can manage risk by predicting extreme events. 2. We […]
Are your assumptions correct? You get a new tool to help manage your processes and everything starts working better. Is everything actually working better? Or is the data just being manipulated to look better? As is often the case, the pointy-haired boss can show us the problem. Often the compliance officer is like the pointy-haired […]
In the Swofford v. Eslinger case, the court sanctioned in-house counsel (but not outside counsel) for failure to preserve evidence. The attorney sanctioned was general counsel for a government entity, the Seminal County Sheriff’s Department. What was unique about this case was that the sanctions were brought against in-house counsel for spoliation of evidence even […]
I’m taking a few days off for the holiday weekend. Image by Das Nili in Wikimedia: Christmas tree near the Quincy Market.jpg
Sing it with me: On the first day of compliance, my audit gave to me: Madoff in a prison jumpsuit. . . On the second day of compliance, my audit gave to me: Two legal frauds, and Madoff in a prison jumpsuit. . On the third day of compliance, my audit gave to me: Three […]
If you live in the Greater Boston area and have $45 lying around, I am speaking on social networking on January 15, 2010 hosted by the New England Chapter of AIIM. Social Networking is Serious Business Newton Marriott Hotel January 15, 2010 8:30 a.m. – 11 a.m. $40 AIIM NE members/$45 non-members I will be […]
With the COBRA subsidy having expired, Congress has moved ahead to extend the subsidy. Section 1010 of the Department of Defense Appropriations Act, 2010 extends the COBRA subsidy program for six more months, moving from a nine month subsidy to a 15 month subsidy. It also extends the eligibility for workers from December 31, 2009 […]
You might think that the United States Office of Government Ethics would be overly serious and lack a sense of humor. You would be wrong. Check out the poem at the end of their Reminder about Holiday Gifts & Fundraising (.pdf) The holiday season – a time for good cheer! For egg nog, for parties, […]
Here are some interesting stories from the past week: “Mr. Ruehle, You Are a Free Man”: Judge Carney’s Dramatic Dismissal of the Broadcom Backdating Criminal Case by Kevin M. LaCroix in The D&O Diary There has been widespread news coverage of the dramatic December 15, 2009 decision of Central District of California Judge Cormac Carney to […]
- Compliance Bricks and Mortar for the July Fourth Weekend
- How to Allocate Broken Deal Expenses After the KKR Case?
- Allocation of Broken Deal Expenses
- SEC Loosens the Standards in Trade Monitoring
- Can a Real Estate Fund Manager Be a Venture Capital Fund Manager?
- Compliance Bricks and Mortar for June 19
- I Ask For Your Money
- The SEC Goes After the Gate Keeper
- Whistleblower Retaliation
- Compliance Bricks and Mortar for June 12
Dodd-Frank’ed Real Estate
- Yes, the SEC Wants Real Estate Fund Managers to Register
- Are Real Estate Fund Managers Registered with the SEC?
- Are you an Investment Company?
- Real Estate Funds and the Investment Company Act
- Are you an Investment Adviser?
- Custody and Private Funds
- Private Equity Real Estate Top 50 – 2015 Edition of Who is Registered