Compliance Bricks and Mortar for June 14

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These are some of the compliance-related stories that recently caught my attention.

Investor Alert—Don’t Trade on Pump-And-Dump Stock Emails

FINRA and the SEC’s Office of Investor Education and Advocacy are issuing this Investor Alert to warn investors to be on the lookout for email spam promoting “pump-and-dump” stock scams.

SEC Compliance Program Annual Reviews: A Guide for Newly Registered Advisers by Nathan J. Greene, Jesse P. Kanach of Shearman & Sterling

Many newly registered investment advisers will need to complete their first annual compliance review this year. This article describes SEC requirements regarding annual reviews of compliance programs and, in particular, covers who should conduct the review, planning and documenting the review, reporting review findings and responding to problematic conduct identified by the review.

SEC’s Cohen Predicts Major Whistleblower Awards Soon in Corporate Crime Reporter

In its three years of existence, the Securities and Exchange Commission’s (SEC) whistleblower program has produced only one $50,000 payout. But within the next couple of months, it will produce “incredibly impactful cases” with “some extremely significant whistleblower awards.” That’s the take of Stephen Cohen, Associate Director of the SEC’s Division of Enforcement.

If DOMA is overturned, will the discrimination in the accredited investor definition go away? by William Carleton

To address the problem of the insidious discrimination in the accredited investor definition, either the term “spouse” will need to be removed, or a constructive definition arrived at.

I’m not sure which solution is better.

I am sure, however, that there will be broad consensus in the angel investing community that the sexual orientation discrimination in the SEC rule is repugnant.

To learn more about this issue, go to http:\\startupequality.com.

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