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Author Archive | Doug Cornelius

Compliance Brought to You by Juno

The Massachusetts Governor declared a travel ban and public transportation has been stopped. That definitely makes it a stay-at-home day for me. I’ll be out shoveling instead of writing about compliance today.

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What’s in your Wallet? Insider Trading

It’s clearly insider when a company’s high-level executive trades on pending earnings data not yet released to the public. It’s clearly not insider trading when you count cars in a retailer’s parking lot to get insight to sales. A recent SEC case falls somewhere in the middle. The Securities and Exchange Commission brought charges against […]

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Compliance Bricks and Mortar for January 23

These are some of the compliance-related stories that recently caught my attention. Equity Crowdfunding: A Market for Lemons? by Darian M. Ibrahim in the CLS Blue Sky Blog Before reaching the more difficult Title III, I reveal that the less-radical Title II, which allows general solicitation of accredited investors, seems to have proven successful for […]

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Massachusetts Adopts Crowdfunding

Add Massachusetts to the growing list of states that are sidestepping the unusable federal crowdfunding alternative. “The Crowdfunding Exemption is designed to foster job creation by helping small and early-stage Massachusetts companies find investors and gain greater access to capital with fewer restrictions. The exemption is also intended to provide necessary investor protections by requiring […]

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Preparation for SEC Examinations

Ascendent Compliance put together a presentation on Preparation for SEC Examinations. Last year the SEC examined 9% of advisers which represent 25% of the RAUM. Of those exams, 87% had deficiencies, 25% had significant findings, and 14% were referred to enforcement. The SEC has implemented a new telephone assessment for offsite remote exams. The examiners […]

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Martin Luther King Jr. Day

It’s the third Monday of January, so that means a day off to celebrate the Birthday of Martin Luther King, Jr. It was officially observed in all 50 states for the first time in 2000. President Ronald Reagan signed a bill creating the federal holiday to honor King in 1983. How to celebrate?

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Weekend Riding – Facing the Cold

That’s me, bundled up for my first bike ride of 2015 on Saturday. I was going to ride first thing in the morning, but shied away when I saw a 9 degree reading on the thermometer. I waited for the balmy afternoon temperature of 22 degrees before enduring a 15 mile ride. Why ride? I’m […]

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Compliance Bricks and Mortar for January 16

These are some of the compliance-related stories that recently caught my attention. RBS Loses Senior Compliance Staff, Some Poached by HSBC by Margot Patrick And Rachel Louise Ensign in the Wall Street Journal The departures come as RBS, 80%-owned by the British government, faces a potential multibillion-dollar settlement with the Federal Housing Finance Agency over […]

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SEC Exam Priorities for 2015

In 2013 the Office of Compliance Inspections and Examinations at the Securities Exchange Commission laid out their examination priorities for 2013 and did so again last year with its 2014 Examination Priorities. OCIE just released its Examination Priorities for 2015. One item jumps out for a focus for private funds: Fees and Expenses in Private […]

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Private Equity Funds and Broker-Dealer Registration

There was a lots of hand-wringing after a speech by David Blass indicated that the SEC was focusing on transaction based fees that private equity funds were earning on securities transactions. Since then, there has been rumblings during presence exams, but no official enforcement action or ruling from the SEC. One group of fees at […]

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