The House Financial Services Committee pushed ahead a bill designed to exempt advisers to certain private equity funds from the new registration requirements imposed by Title IV of the Dodd-Frank Act. The Small Business Capital Access & Job Preservation Act was presented last session, and Congressman Hurt has brought it back again. Except as provided […]
About Doug Cornelius
Section 413 of the Dodd-Frank Act requires the Securities and Exchange Commission to review the accredited investor definition by July 21, 2014, the fourth anniversary of President Obama’s signing of the law. In a letter to Congressman Scott Garrett, SEC Chair Mary Jo White said that the Commission staff has begun a comprehensive review of the accredited […]
The SEC slapped a fund manager and its out-sourced CCO. The main charge was engaging in undisclosed principal transactions. Beyond that obvious conflict issue, the order has some interesting statements about failures in the compliance program. Parallax Investments, LLC, a Houston based firm, registered with the SEC as investment adviser in 2010. It also had […]
So, for the first time since 1888 both Thanksgiving AND Hanukkah fall on the same day. Enjoy some time off with friends and family. I am.
SEC Rule 206(4)-5 for investment advisers and fund managers limits the ability of a firm’s employees to make political contributions. It’s a nasty rule. Violation of the rule does not require any bad intent. The breadth of affected political candidates is long, diverse, and hard to discover. Anthony Yoseloff worked at Davidson Kempner Capital Management […]
These are some of the compliance-related stories that recently caught my attention. JP Morgan’s Twitter Mistake by Emily Greenhouse in the New Yorker This is Twitter’s very purpose: to allow any individual to share the same space with, for instance, a hugely powerful bank. With this space comes attention and authority. Unlike at JPMorgan’s Park […]
What is the proper role of business? Ben W. Heineman Jr. served as the senior vice president and general counsel of GE for 15 years so he has some sense of the role of business. During that period GE was one of the most respected and valuable companies in the world. Mr. Heineman has an […]
It was an unusual show of bipartisan support when the original JOBS Act was passed in the Spring of 2012. Congress is following in the footsteps of movie studios and looking to produce a sequel. Financial Services Committee Chairman Jeb Hensarling has promoted a group of bills that he thinks will comprise the JOBS Act […]
Last week, the SEC’s Division of Investment Management released a guidance update that focuses on funds that use a name that “suggests safety or protection from loss.” The IM Guidance Update is a shot across the bow, warning a fund to considering changing its name if it exposes investors to “market, credit, or other risks.” […]
The new Rule 506(c) is a big substantive change on how private placements can be run. That leaves many, including me, with a lot of questions. The Securities and Exchange Commission just posted a series of new questions and answers on the new rule. Most of the answers are expected confirmations, but there are a […]
- Small Business Capital Access & Job Preservation Act – Part 2
- The Upcoming Changes to the Accredited Investor Standard
- Compliance Program Failure
- Happy Thanksgivukkah!
- Some Relief for a Fund Manager Under the Political Contributions Rule
- Compliance Bricks and Mortar for November 20
- High Performance with High Integrity
- JOBS Act 2.0
- Is Your Fund Name Misleading?
- You Got Questions About 506(c) – The SEC Has Answers