Compliance Bits and Pieces for February 17

These are some compliance-related stories that recently caught my attention:


Lessons Learned on Compliance and Ethics by Tom Fox

In [Lessons Learned on Compliance and Ethics: The Best from the FCPA Compliance and Ethics Blog ] I have collected some of my posts which I think will help guide you in your own journey through the world of anti-corruption and anti-bribery compliance. I have broken the book down into the following chapters:

  • Some Thoughts on Best Practices
  • The Nuts and Bolts of Compliance
  • Investigations, Enforcement Actions and Legal Issues
  • Summing It All Up

Compliance Rocks: Adele is Phat (And Teaches Compliance Lessons) by Paul Liebman in Corporate Compliance Insights

Sidewalks are paved but students walk where they want to walk. Makes sense to me. Students want to get where they are going as quickly and directly as possible and do not feel the need to follow a path just because it has been paved.

Upcoming 2012 SEC Regulatory Deadlines in Compliance Avenue

Congratulations to all newly registering investment advisers that have submitted their Forms ADV Part 1A and Part 2A via the Investment Adviser Registration Depository (“IARD”) in anticipation of the March 30, 2012 deadline! The Securities and Exchange Commission (“SEC”) generally has up to 45 days after receipt of the Form ADV to declare the registration effective and generally will notify an adviser via email once its registration is declared effective. Registrations may be declared effective at any time during that 45-day period. An adviser can also check on IARD under the heading “Registration/Reporting Status” to see if its registration has been declared effective. Below is a review and reminder of certain of the annual regulatory requirements that may be applicable to investment advisers…

Financing, Fundraising, Pre-Selling Are Starting to Blur… by William Carleton

It’s a reminder, as we watch some kind of crowdfunding securities law exemption develop in Congress, that there are other things to sell besides a share in the profits of a business. Does it mean that selling shares in the profits of a business are not interesting? Certainly not. But add another means to bypassing equity financing at the outset. This is not your grandfather’s bootstrapping.

Annals of private equity, Tamara Mellon edition By Felix Salmon

It’s always love and kisses when a private-equity company takes control of your firm: they promise investment, and growth, and riches beyond your wildest dreams. All of which came true for Mellon (who acquired her surname by marrying a man with 14 trust funds, but that’s another story). But then the clock strikes midnight, and your eager backers are forced — they have LPs to answer to, after all — to sell your company out from under you.

SEC to elevate role of the CCO By Jim Kim in FierceComplianceIT

In the nitty-gritty of an enforcement situation, smart companies are realizing that they will get credit from the regulators if they have appropriate compliance policies in place.

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