Comments on: Draft SEC Strategic Plan for 2010-2015 http://www.compliancebuilding.com/2009/10/08/draft-sec-strategic-plan-for-2010-2015/ Doug Cornelius on compliance and business ethics for private equity real estate Mon, 13 Feb 2012 12:56:20 +0000 hourly 1 http://wordpress.org/?v=3.3.1 By: Valuable Internet Information » Draft SEC Strategic Plan for 2010-2015 | Compliance Building http://www.compliancebuilding.com/2009/10/08/draft-sec-strategic-plan-for-2010-2015/comment-page-1/#comment-2049 Valuable Internet Information » Draft SEC Strategic Plan for 2010-2015 | Compliance Building Fri, 09 Oct 2009 17:09:02 +0000 http://www.compliancebuilding.com/?p=4538#comment-2049 [...] Originally posted here:  Draft SEC Strategic Plan for 2010-2015 | Compliance Building [...] [...] Originally posted here:  Draft SEC Strategic Plan for 2010-2015 | Compliance Building [...]

]]> By: Doug Cornelius http://www.compliancebuilding.com/2009/10/08/draft-sec-strategic-plan-for-2010-2015/comment-page-1/#comment-2047 Doug Cornelius Fri, 09 Oct 2009 12:22:27 +0000 http://www.compliancebuilding.com/?p=4538#comment-2047 Jeff - As they point out in the discussion of Strategic Goal 1, they want to stop the next Madoff. Inevitably, with a focus on IAs, BDs and private investments, the next problem will come from public companies or investment companies. Jeff –

As they point out in the discussion of Strategic Goal 1, they want to stop the next Madoff.

Inevitably, with a focus on IAs, BDs and private investments, the next problem will come from public companies or investment companies.

]]> By: Jeff Kaplan http://www.compliancebuilding.com/2009/10/08/draft-sec-strategic-plan-for-2010-2015/comment-page-1/#comment-2046 Jeff Kaplan Fri, 09 Oct 2009 10:40:57 +0000 http://www.compliancebuilding.com/?p=4538#comment-2046 Doug, Interesting to see that while the SEC recognizes that it should promote compliance programs both among regulated entities and public companies (pp 10-11) all the performance metrics for this part of the plan are related to the former. This is unfortunate because public company compliance programs are obviously important as well - but it is consistent with the SEC's track record to date in this area. Hopefully, they will receive comments encouraging them to do more to promote public company compliance programs, too - particularly by crediting such programs (under the policy established by the Seaboard case) in a more public way than they presently do. Doug, Interesting to see that while the SEC recognizes that it should promote compliance programs both among regulated entities and public companies (pp 10-11) all the performance metrics for this part of the plan are related to the former. This is unfortunate because public company compliance programs are obviously important as well – but it is consistent with the SEC’s track record to date in this area. Hopefully, they will receive comments encouraging them to do more to promote public company compliance programs, too – particularly by crediting such programs (under the policy established by the Seaboard case) in a more public way than they presently do.

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