About Doug Cornelius

Author Archive | Doug Cornelius

Best Practices Under the FCPA and Bribery Act

Tom Fox is prolific writer on the Foreign Corrupt Practices Act. He publishes the excellent FCPA Compliance and Ethics Blog. One of the downsides to a blog is that it’s a running commentary and not a narrative guide. Blogs are great for sharing ideas among practitioners. But a blog does not come together as a […]

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The SEC Expresses Its Displeasure on Fund Fees

A few days ago, Bloomberg published a story that the Securities and Exchange Commission has examined about 400 private equity firms and found that more than half charged “unjustified fees and expenses without notifying investors”. The SEC followed through with that story and recently charged Total Wealth Management with improperly disclosing fee revenue. Total Wealth […]

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Real Estate Investing and Crowdfunding

Real estate investing is capital-intensive. It should be a natural area for crowdfunding. The big concern is fees and conflicts. With a tech startup, you are investing in an idea and the people with the idea. It may grow exponentially or blow up, leaving little behind. Part of the investment is paying the people to […]

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Compliance Bricks and Mortar for April 11

Charles Ponzi’s former home up for sale by Erin Ailworth For the first time, the butter-colored stucco house with the slate roof and second-story balustrades, is going on the broader real estate market, available to anyone willing to take a run at the $3.3 million asking price. All previous sales have been private. One of […]

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Pay to Play and the Supreme Court

The US Supreme Court struck down some campaign finance limitations in McCutcheon v. Federal Election Commission. My first question was whether this court ruling would impact the Securities and Exchange Commission’s Rule 206(4)-5. The answer is “no.” Mr. McCutcheon wanted to contribute $1776 dollars to a long list of political candidates. Each individual contribution is […]

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Can a Vending Machine Be a Security?

The Securities and Exchange Commission brought charges against Joseph Signore and Paul Lewis Schumack, II in connection with an alleged investment fraud concerning the sales and marketing of a “Virtual Concierge” machine. The machine looks like an ATM, but carries advertising and can print tickets and coupons. It looks shady, but a machine alone is […]

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The SEC Has Seen Your Private Equity Fees And Is Not Happy With Them

According to a story in Bloomberg, the Securities and Exchange Commission has examined about 400 private equity firms and found that more than half have charged “unjustified fees and expenses without notifying investors”. The editor decided to change the headline from “unjustified” to “bogus”. Fees and expenses charged by a fund manager to investors in […]

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What Are the Implications of the SEC’s New Private Fund Exam Unit

Greg Roumeliotis and Sarah N. Lynch are reporting in Reuters that the Securities and Exchange Commission has formed a new group dedicated to the exam of private equity and hedge funds. This new private fund unit will be co-chaired by Igor Rozenblit and Marc Wyatt. Rozenblit is coming from the asset management unit of the […]

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Compliance Bricks and Mortar for April 4

These are some of the compliance-related stories that recently caught my attention. Small Banks Look to Sell as Rules Bite by Michael Rappaport in the Wall Street Journal In a period when low interest rates are squeezing small banks, the costs of adhering to new regulations are taking a toll. Executives from at least a […]

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Accredited Investor Verification

When Congress imposed a lifting of the ban on advertisements for private placements, it also imposed a mandate that the fundraiser “take reasonable steps to verify that purchasers of the securities are accredited investors.” The methods for verification were to be determined by the Securities and Exchange Commission. The SEC, to its credit, did not […]

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