About Doug Cornelius

Author Archive | Doug Cornelius

Getting Caught With IPO Fever

A decade ago shares in an initial public offering were handed out as gifts to curry favor with business executives. The shares were all but guaranteed to pop on the opening day for an easy gain. The recent Twitter IPO had that similar feeling of a guaranteed pop. Gregory Gray thought he could make some […]

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SEC Guidance On Gifts and Entertainment Compliance

Any story about the SEC, funds, gifts will catch my attention. Last week, the Staff of the SEC’s Division of Investment Management issued IM Guidance Update No. 2015-1 on gifts and entertainment in the fund industry. The Guidance refers to section Section 17(e)(1), which did not seem familiar to me. The reference is to the […]

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Compliance Bricks and Mortar for February 27

These are some of the compliance-related stories that recently caught my attention. SEC Commissioners Push Lifetime Bans on Executives by Joel Schectman in WSJ.com’s Risk & Compliance Journal The U.S. Securities and Exchange Commission is divided over whether it should impose severe restrictions on banks and their executives who break securities rules. For top executives, […]

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Dislocated in Wyoming Again

At the fall NRS Conference, the presenter and the audience were both surprised to reveal that false addresses was a new enforcement initiative for the Securities and Exchange Commission when it came to registered investment advisers and fund managers. Two weeks ago, the SEC came out with three enforcement actions against advisers that had falsely […]

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Compliance Bricks and Mortar for February 20

It’s been a tough week in Boston dealing with the historic level of snow. As of February 17, the snow depth near Boston was greater than in all but two reported locations in Alaska. It was significantly higher than the notoriously snowy states of Michigan, Wisconsin, and Minnesota. Only Buffalo, New York, had a higher […]

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Compliance Bricks and Mortar for February 13

These are some of the compliance-related stories that recently caught my attention. The S.E.C.’s Hazy Approach to Crime and Punishment by Peter J. Henning in NY Times.com’s DealBook In Gilbert and Sullivan’s “The Mikado,” a line expresses the need “to let the punishment fit the crime.” The Securities and Exchange Commission is struggling with that […]

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Looking for Signs

Compliance is all about looking for signs. You want signs that employees understand the rules. You want signs that mistakes are being spotted and fixed before they become bigger problems. You want signs that big problems are being smartly corrected. Those signs take many forms. You can monitor hotline calls. You can have employees repeatedly […]

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The Lure of Wyoming

There is a long history of splitting financial regulatory oversight between state regulators and federal regulators. For investment advisers the split is based on Assets Under Management and Dodd-Frank raised the AUM level from $25 million to $100 million. Above that level you register with the SEC and below that level you register with the […]

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Testing for the Avalanche

As Nassim Nicholas Taleb famously explained in The Black Swan, it is the unexpected that is most unexpected. For compliance professionals, testing is one of the tools that tries to expose the unexpected. I was thinking about testing as I was out in the snowpack in my front yard. I tried out some of the […]

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Making a Bigger Compliance Mistake After Making a Big Compliance Mistake

Total Wealth Management became one of the whipping boys for the Securities and Exchange Commission when it started its focus on private fund fees last year. The firm settled with the SEC and agreed to pay the fine. But the firm exacerbated the problem by allegedly misappropriating the money from its clients. Last year, the […]

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