I remember the days of the mimeograph. In class people would inevitably sniff the newly printed pages. For a teacher, the danger was that the latent copy would fall into the wrong hands. Animal House highlighted that danger. Current day copiers are much more advanced than the mimeograph, but the dangers of the latent copy [...]
Archive | February, 2011
Compliance Bits and Pieces for February 25
Here are some compliance-related stories that caught my eye: A Blank Check for Cleaning Up Madoff’s Mess by Floyd Norris in the New York Times But the Bernard L. Madoff fraud is proving to be different, and not just because Mr. Madoff ran by far the largest Ponzi scheme ever encountered. … SIPC (pronounced SIP-ick), [...]
Placement Agent Limitations on Gifts
The Municipal Securities Rulemaking Board is continuing to tighten the limits on what placement agents can do as part of their fundraising activities for private funds. Dodd-Frank created a new category of “municipal advisors” and placed them under the regulatory oversight of the MSRB. If your fund uses a placement agent and has government-sponsored investors [...]
Egypt, Mubarak and Politically Exposed Persons
Egypt’s top prosecutor requested the freezing of the foreign assets of ousted president Hosni Mubarak and his family. I expect that is one step in trying to figure out how much of Mubarak’s fortune was derived from corruption. I’ve read reports that his assets could be worth $3 billion and upwards of $70 billion. That [...]
The SEC is Looking at Advisers’ Use of Social Media
According to a story in Investment News, the Securities and Exchange Commission began a sweep of investment advisers’ use of social media and social networking last month. The story hast a quote from Doug Flynn, an adviser at Flynn Zito Capital Management LLC, that is exactly on target for traditional investment advisers: “I’d love to [...]
Read a Free Book
I have an extra copy of All the Devils are Here by Bethany McLean and Joe Nocera. They put together an insightful look at the many factors that created the housing bubble and amplified the destruction when it popped. Pundits and purists have tried to pin the blame on a single element. It seems clear [...]
The Amish Madoff
The Securities and Exchange Commission filed charges against Monroe L. Beachy, a 77-year-old Amish man from Sugarcreek, Ohio. They found the Bernie Madoff of the Amish. Beachy targeted his fellow Amish in his alleged fraud. He raised more than $33 million from as early as 1986. Beachy enticed investors by promising interest rates that were [...]
Looking at the Residential Mortgage Crash
Matt Phillips at WSJ.com’s Market Beat put together some great charts showing the problems with the residential mortgage market: Fannie and Freddie: The Saga in Charts. The first one that caught my eye shows how Wall-Street took such a quick, big chunk of the market share of residential mortgage-backed securities during the housing boom. Fannie [...]
Are ETFs Reportable Securities?
As a compliance officer for a registered investment adviser, you need to verify transactions where the account has a “reportable security” to make sure your employees are not violating your insider trading policy. That means checking you employees’ securities accounts at least quarterly. You’re compelled by Rule 204A-1 (b)(2) to do this for access persons. [...]
Celebrate Valentine’s Day with a Regulatory Twist
As someone who stares at a lot of regulations, this Valentine’s Day message caught my eye. If you are a fan of NPR, they have several other ways to share Valentine’s Day with an NPR flavor. And don’t forget about the compliance issues you can run into. Dan Schwartz compiled a bunch of bungled romance [...]
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