Compliance Bricks and Mortar for September 9

compliance bricks and mortar

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

Bad news. You’re promoted to compliance officer by Michael Scher in The FCPA Blog

It’s not right to lump together all compliance officers. We have to recognize that those working in America are nearly on another planet from COs working in Asia, Africa, Latin America, Russia and many other countries. While all compliance officers may be speaking the “same language,” the conditions of speaking truth to management or regulators are incomparably different.

Where is Crowdfunding? by Dave Lynn in The CorproateCounsel.net

Well over a year after the enactment of the JOBS Act, we still await movement on the SEC’s rulemaking under Title III, which provides the framework for exempt crowdfunding offerings to non-accredited investors, subject to a $1 million cap over a rolling 12-month period and dollar limits based on an investor’s financial position. As this Washington Post article notes, the SEC Staff has indicated that crowdfunding rules can be expected sometime this fall, however these would presumably be proposed rules, meaning that final rules could not be expected until well into 2014 at the earliest when you factor in the need for FINRA to also create a regulatory system for funding portals. As a result, the ability to do exempt crowdfunding offerings remains limited, except that many are anticipating the ability to do more accredited investor-only crowdfunding offerings once general solicitation is permitted under Rule 506 after the September 23, 2013 effective date of those JOBS Act mandated rule changes.

More Questions About General Solicitation by Joe Wallin in Startup law Blog

There is a lot of confusion about the SEC’s new rules that will allow, starting September 23rd, the general solicitation and general advertisement of private company securities offerings under Rule 506(c) of Regulation D.

Send in the Clowns – the NCAA and its Investigation of Johnny Football by Tom Fox in FCPA Compliance and Ethics Blog

How can you determine if an organization charged wijth compliance is corrupt or simply incompetent? It is hard today to answer that question when it comes to the National Collegiate Athletic Association (NCAA) and its enforcement division. For those of you do not know the story, the NCAA was investigating last year’s Heisman Trophy winner, Johnny Manziel a/k/a Johnny Football, for allegedly signing autographs for money, which is a violation of the near slavery conditions that NCAA scholarship athletes find themselves in today.

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