Compliance Bricks and Mortar for March 31

It’s been a busy week, getting information and drafting for the Form ADV filing. I have a big stack of stories to read and write, but these are some of the compliance-related stories that recently caught my attention.


United’s Policy Management Lessons by Matt Kelly in Radical Compliance

Compliance officers who want a glimpse of your future, look no further than the spectacle that unfolded Sunday morning at Denver International Airport: a tale of policy management mismanaged, reputation risk, and plenty of commentary on social media.

Some day, some way, a headache like this will be yours. This time the lucky company was United Airlines. Let’s taxi into this teachable moment. [More…]


The myth of the 70,000-page federal tax code by Dylan Matthews in Vox

The US tax code is definitely complicated at points, so it’s no wonder that the claim that it is 70,000 pages long has become a widely cited factoid, most recently in messaging from Republicans on the House Ways and Means Committee, the committee that’s leading the Republican effort to simplify and reform income taxes:

The only problem with this claim is that it’s clearly false. As of 2014, the tax code was only about 2,600 pages long. [more…]


SEC Private Equity Enforcement: A More Aggressive Approach by Andrew J. Lichtman and Howard S. Suskin in the Compliance & Enforcement blog sponsored by NYU Law’s Program on Corporate Compliance and Enforcement

Over the last several years, the Securities and Exchange Commission (“SEC”) has targeted private equity funds for various fee allocation arrangements and conflicts of interest.  Rather than describing the fee practices as fraudulent, which would require a showing of scienter, the SEC has concluded that the private equity advisers committed disclosure violations.  However, a recent proceeding in which the SEC secured a settlement based on both breach of fiduciary duty and fraud may foreshadow a more aggressive approach.  Some context first. [more…]


Why the SCCE and HCCA Don’t Care by Adam Turteltaub in the SCCE’s Compliance & Ethics Blog

With a combined membership of over 17,000 dues-paying individuals, the SCCE and HCCA are, obviously the go-to resource for compliance professionals. And, it’s also the go-to resource for vendors wanting to reach compliance professionals.

And, from time to time, those vendors will ask for an endorsement, to offer special discounts to our members, or want their product or work formally recognized. Inevitably, and to them dismayingly quickly, we say no. [More…]


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