Archive | October, 2010

Jim Cramer’s Sound Board

From CNBC’s Mad Money: We’ve Recreated Cramer’s Official Soundboard! Fun for any Mad Money fan, you can enjoy all the great sounds on Cramer’s board. Boo-Yah! Yes, the buttons make sounds.

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Compliance Bits and Pieces for October 29

These are some recent compliance-related stories that caught my eye: Take A Seat, and Other Bribes by Scott Greenfield in Simple Justice And if you don’t think the FCPA matters to you, who do you think it paying the many millions of dollars forked over to lawyers and government, not to mention the opportunity costs [...]

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Coffee and Compliance

I just sat down with a fresh cup of coffee from Green Mountain Coffee Keurig brewer. The smell of coffee mixed with stench of compliance failures coming from Green Mountain Coffee Roasters, Inc. You know there is trouble when Sam Antar, the convicted felon and criminal CFO of Crazy Eddie, has you in his sights. [...]

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The LexisNexis Top 25 Business Law Blogs of 2010

In a clear case of voting error, LexisNexis decided to include Compliance Building in the LexisNexis Top 25 Business Law Blogs of 2010. I’m regular reader of most of those 25 blogs and think they’re wonderful. I’m happy to be included with such great content sites. For some reason, LexisNexis is not satisfied with just [...]

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More Information on the Custody Rule

More Information on the Custody Rule

With the removal of the 15 client rule exemption from registration with the SEC, many private funds are going to have to comply the custody rule Rule 206(4)-2. Private equity firms will have the most problems trying to meets the demands of the rule. The SEC is trying to help. They updated the Staff Responses [...]

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Lawyers and Corruption Laws

Lawyers and Corruption Laws

In April 2010, the International Bar Association, the Organisation for Economic Co-operation and Development and the United Nations Office on Drugs and Crime, launched the Anti-Corruption Strategy for the Legal Profession. The project is focusing on the role lawyers play in fighting corruption in international business transactions. Nearly half of all respondents recognized corruption to [...]

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Don’t Lie to the Feds When Caught for Insider Trading

Don’t Lie to the Feds When Caught for Insider Trading

The “classical theory” of insider trading targets “a corporate insider’s breach of duty to shareholders with whom the insider transacts[, and the] misappropriation theory outlaws trading on the basis of nonpublic information by a corporate ‘outsider’ in breach of a duty owed not to a trading party, but to the source of the information.” See [...]

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Compliance Bits and Pieces for October 22

Here are some recent compliance related stories: Trusted Transactions, or Trusted Relationships? by Charles H. Green in Trust Matters Much of the public dialogue today confuses these two distinctions. Is it Congress that people don’t trust? Or is it members of Congress who themselves are considered untrustworthy? To the average voter, it’s a distinction without [...]

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The International View on US Anti-Bribery Efforts

The Organization for Economic Cooperation and Development’s report on U.S. anti-bribery efforts released their Phase 3 Report on the United States. In its report, the Working Group commended the United States for its engagement with the private sector, substantial enforcement, and commitment from the highest levels of the U.S. Government. In addition to the recommendation [...]

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SEC Complaint Reads Like a List of Things Not to Do

SEC Complaint Reads Like a List of Things Not to Do

SEC complaints usually contain great stories about what you should not to do. A recent case involving PEF Advisors caught my eye. The SEC claimed that hedge fund managers Paul Mannion, and Andrew Reckles, and their investment advisory company PEF Advisors misappropriated investor cash and securities by using the “side pockets” in 2005. When used [...]

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