Back in December, the Federal Trade Commission released new guidelines that specifically required bloggers to disclose any material connections to a product or company they are writing about. In May, they brought their first action under those guidelines against Ann Taylor. The FTC declined to bring an enforcement action. Last week, they brought their second [...]
Archive | August, 2010
Book Review: Rewired
I think a big part of compliance is education. It is great to get compliance imposed through internal systems, but you generally need to get the message out to your company about the policies, why they exist, and what they need to do. There is lots of talk about the generation and age group starting [...]
Compliance Bits and Pieces for August 27
Here are some recent stories I found interesting: A Red Flag on G.M. Internal Controls by Peter J. Henning in the New York Times’ DealBook General Motors filed its S-1 on Wednesday, and its list of potential risks to the company contains the usual array of obvious market threats and uncontrollable events that might be [...]
How to Get Caught Insider Trading
Purchase out of the money call options set to expire in two weeks, be an employee of the company acting as an adviser in the merger, not have any activity on that stock before, use an account in your name, exclusively use option when you have barely traded options in the account before, and quickly [...]
Social Media as a Risk Factor
It’s official. Social media is a risk factor. At least according to Estee Lauder and lululemon athletica. Over at Footnoted, Michelle Leder and her team dig through SEC filings digging up the dirt on bad corporate behavior. They were digging through the 10-K for Estee Lauder when Theo Francis came across a new risk factor. [...]
Can Companies Do Well by Doing Good?
Yesterday’s Wall Street Journal published a story by Aneel Karnani, Professor of Strategy at the University of Michigan’s Stephen M Ross School of Business with a controversial headline: The Case Against Corporate Social Responsibility. He manages to pull in some corporate governance arguments: “The movement for corporate social responsibility is in direct opposition, in such [...]
Roger Clemens and Lying to the Feds
Roger Clemens taught us another important lesson in dealing with an investigation. Never lie to the feds. Mark McGwire essentially proclaimed his guilt when he refused to answer questions about steroid use during his playing career at a congressional hearing. He may have lost in the arena of public opinion, but he will not have [...]
Compliance Bits and Pieces: Ground Zero Mosque Edition
One part of compliance is investigation. Find the facts. Don’t rely on opinion or self-interest statements. With all the hullabaloo about the Ground Zero Mosque I thought I would gather some factual information. First off. It’s not at Ground Zero. Just How Far Is the “Ground Zero Mosque” From Ground Zero? by Matt Sledge in [...]
SEC versus New Jersey
Fuggedaboutit! New Jersey became the first state ever charged by the SEC for violations of the federal securities laws. They gave up without a fight and agreed to settle the case, without admitting or denying the SEC’s findings. This matter involves the sale of over $26 billion in municipal bonds from August 2001 through April [...]
Criminal Provisions under Dodd-Frank
When thinking designing compliance programs, I pay extra attention to the issues that can result in jail time. It’s one thing to pay a fine, it’s a much bigger problem when you take someone’s freedom away. The Dodd-Frank Wall Street Reform & Consumer Protection Act has added several new federal criminal offenses. The National Association [...]
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