One of the key rules for private investment funds is that their investors generally need to be “accredited investors.” This is the gateway to an exemption from the registration requirement under the federal securities laws. The exemption is generally targeted so that experienced investors with significant financial resources and their own advisers are in less [...]
Archive | October, 2009
Canada’s Foreign Corrupt Practices Act
In the United States, the Foreign Corrupt Practices Act has received significant attention due to some recent high-profile prosecutions. Just to the North, there is the Canadian equivalent to the FCPA: the Corruption of Foreign Public Officials Act. It has not yet been a significant concern for most businesses that fall within its jurisdiction. But [...]
Happy Columbus Day
I decided to take the day off for Columbus Day. School is closed and the office is closed. Although, I posted this picture. So I guess I did something related to compliance.
Calendars and Household Compliance
It is hard to keep track of who is doing what with a busy family. You can’t show up on time and do what you are supposed to do if you don’t where you are supposed be. My work calendar runs on an Exchange / Outlook platform, as does The Wife’s calendar. Now that The Son [...]
Compliance Bits and Pieces
Here is this weeks collection of stuff I found interesting, but didn’t blog about: To Combat Overseas Bribery, Authorities Make It Personal Dionne Searcy for The Wall Street Journal “To really achieve the kind of deterrent effect we’re shooting for, you have to prosecute individuals,” Mark Mendelsohn, deputy chief of the Justice Department’s criminal division, [...]
FINRA Is Thinking About Changing Its Communications Rules
Financial Industry Regulatory Authority (FINRA) posted a regulatory notice on proposed new rules governing member communications with the public: Regulatory Notice 09-55. The new rules would replace current NASD Rules 2210 and 2211, the Interpretive Materials that follow NASD Rule 2210, and portions of Incorporated NYSE Rule 472. The proposal would replace the existing six [...]
Draft SEC Strategic Plan for 2010-2015
The Securities and Exchange Commission is seeking comment on its draft Strategic Plan. The document includes drafts of the SEC’s mission, vision, values, strategic goals, major initiatives, and performance metrics for fiscal years 2010 through 2015. Draft SEC Strategic Plan for 2010-2015 Here is the new vision: The SEC strives to promote a market environment [...]
The CFO’s and CCO’s Role in Fundraising
Yesterday, I attended the PERE Real Estate CFOs Forum. These are my notes from this session: Moderator: Steve Felix, Head of Client Relations-Real Estate, Aviva Investors Ira Bergstein, Principal & CFO, Palisades Financial, LLC Jack Foster, Head of Real Estate, Franklin Templeton Real Estate Advisors Asha Richards, Vice President & General Counsel for the Private [...]
Managing Private Real Estate Funds – The Changing Role of the CFO and Chief Compliance Officer
Yesterday, I attended the PERE Real Estate CFOs Forum. These are my notes from this session. Moderator: Gary Koster, Americas Leader- Real Estate Fund Services, Ernst & Young LLP Peter C. Cluff, Principal, Europa Capital LLP Stuart Koenig, Global CFO & Chief Administrative Officer, AREA Property Partners Dominic Petrucci, Chief Financial Officer, Buchanan Street Partners [...]
Debt: The Missing Link
Yesterday, I attended the PERE Real Estate CFOs Forum. These are my notes from this keynote session by Schecky Schechner, Managing Director, US Head of Real Estate Investment Banking, Barclays Capital. There is a wave (a wall?) of real estate debt maturities coming due over the next three years. He started talking about the private [...]
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