About Doug Cornelius

Author Archive | Doug Cornelius

Compliance and the Presidential Candidates

With the New Hampshire primary complete, the field of presidential candidates will continue to become smaller. Some of those dropping out may lower their expectations to Vice President or go back to their day jobs. Registered investment advisers have to worry about those day jobs when it comes to campaign donations. Under SEC Rule 206(4)-5, […]

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Compliance and the Super Bowl Victory

Defense wins championships. It’s an old sport cliche. However, the Denver Broncos proved it last night in the Super Bowl. The Orange Crush neutralized the NFL’s MVP, Cam Newton. Peyton Manning rounded off his career, landing win 200. Mr. Manning still has the most playoff losses of any quarterback. Of course that is because he […]

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Weekend Watching

You may have missed Madoff on ABC this week. It’s four hours on the life of the fraudster, portrayed by Richard Dreyfuss. If you have a few hours this weekend, it’s worth watching. Mr. Dreyfuss does a great job portraying Madoff, capturing him lying, cheating and stealing, but looking upstanding in the eyes of his […]

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compliance bricks and mortar

Compliance Bricks and Mortar For February 5

These are some of the compliance-related stories that recently caught my attention. The Most Thankless Job on Wall Street Gets a New Worry: Recent enforcement actions find compliance officers personally liable by Emily Glazer in the Wall Street Journal Those officers on Wall Street in charge of ensuring that traders and other employees stay on […]

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New ILPA Fee Reporting Template

Investors look for transparency in fees. The Institutional Limited Partners Association published a Fee Reporting Template Last Week to encourage uniformity in the fee disclosures being made to private fund investors. The aim of this proposed template is to encourage increased uniformity in the fee disclosures the fund managers provide to limited partners in private […]

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The Good, Bad and the Ugly of Lending

In browsing through the Wall Street Journal I ran into three stories side by side: China Calls Lending Platform Ezubo a $7.6 Billion Ponzi Scheme J.P. Morgan Acquires Nearly $1 Billion Worth of Lending Club Loans Remember ‘Liar Loans’? Wall Street Pushes a Twist on the Crisis-Era Mortgage Each is a different side of specialty […]

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Femke Van den Driessche

It’s Hard to Tell What the Next Form of Cheating Will Look Like

One of the problems with compliance is that the fraudsters seem to be one step ahead of the regulators. The regulators try to push out rules to prevent bad behavior. Regulators look at their charges to find cheating. But the cheaters are often one step ahead. We saw this in professional cycling over the weekend. […]

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brick detail

Compliance Bricks and Mortar for January 29

These are some of the compliance-related stories that recently caught my attention.   U.S. Banks Cut Off Mexican Clients, as Regulatory Pressure Increases by Rachel Louise Ensign, Emily Glazer and Amy Guthrie in the Wall Street Journal At issue are correspondent-banking relationships that allow Mexican banks to facilitate cross-border transactions and meet their clients’ needs […]

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Miami skyline

A Small Step Forward in Real Estate Anti-Money Laundering

Real estate in the United States has been rumored to be an interesting place for hiding money. In particular, the US Treasury is concerned about illegal money getting filtered through US real estate. Until now, FinCEN has mostly relied on anti-money laundering protections on real estate transactions involving lending. FinCEN is now looking at vulnerabilities […]

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The SEC’s Insider Trading Case Falls Further Apart

Five years ago, the SEC came crashing into the offices of Level Global Investors accusing it of engaging in illegal insider trading. The firm agreed to pay $21.5 million in settlement money to resolve that insider trading investigation. Now it wants its money money back. When it comes to insider trading, it’s not the firm […]

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