These are some of the compliance-related stories I set aside to read this holiday weekend. What Do Rating Agencies Think about “Too-Big-to-Fail” Since Dodd-Frank? by Gara Afonso and João Santos in Liberty Street Economics Is it possible that, while S&P still expects support for some BHCs, the perceived strength of support has decreased and is […]
About Doug Cornelius
The Securities and Exchange Commission charged Kohlberg Kravis Roberts & Co. (KKR) with misallocating more than $17 million in “broken deal” expenses to its private equity funds as a breach of KKR’s fiduciary duty. The SEC felt that KKR should not have charged all of those broken deal expenses to the Fund. But how should […]
The Securities and Exchange Commission charged Kohlberg Kravis Roberts & Co. (KKR) with misallocating more than $17 million in “broken deal” expenses to its private equity funds. The SEC found this to be a breach of KKR’s fiduciary duty. An SEC investigation found that from 2006 to 2011, KKR incurred $338 million in broken deal […]
One of the more difficult aspects of a private equity fund when it registers as an investment adviser is dealing with the Rule 204A-1 requirement of monitoring employee trading. The SEC recently issued guidance on the applicability to managed accounts when there is no direct or indirect influence or control. The Guidance focuses on the […]
The Dodd-Frank Wall Street Reform and Consumer Protection Act split the world of fund managers into a few groups. One group that was able to grab a limited exemption from the Investment Advisers Act registration was venture capital fund managers. What does it take to be a venture capital fund manager? And could a real […]
These are some of the compliance-related stories that recently caught my attention. Ethisphere Announces the 2015 Attorneys Who Matter Honorees represent all areas of practice including federal agencies, in-house counsel, top ethics and compliance officers of major companies, and outside counsel. Each one raises the bar for ethical behavior and boasts a commendable track record […]
Compliance Building is a free resource I publish for me, and share with you, to help the compliance profession. It will still be free, but I’m asking for money. I should point out that the money is not for me; It’s for charity. I’m riding the 2015 Pan-Mass Challenge to raise money for the Dana-Farber […]
When a fraud is uncovered, the Securities and Exchange Commission no only wants to get the fraudsters, it also wants to get those who should have stopped the fraud. The SEC just brought an action against an IRA Custodian for ignoring red flags for its accounts that invested in Ponzi schemes. The underlying fraud was […]
A year ago, the Securities and Exchange Commission charged Paradigm Capital Management with engaging in prohibited transactions and then retaliating against the head trader who reported the trading activity to the SEC. It was the first time the SEC filed a case under its new authority to bring anti-retaliation enforcement actions. Now it has handed […]
These are some of the compliance-related stories that recently caught my attention. Jamie Dimon Says He’s Unsure If Elizabeth Warren Understands Global Banking System by Kim Chipman for Bloomberg [W]hen asked about his biggest worries, Dimon expressed concern that the U.S. may eventually be hurt by ideological decisions being made in Washington. [More…] Legal Ethics […]
- Compliance Bricks and Mortar for the July Fourth Weekend
- How to Allocate Broken Deal Expenses After the KKR Case?
- Allocation of Broken Deal Expenses
- SEC Loosens the Standards in Trade Monitoring
- Can a Real Estate Fund Manager Be a Venture Capital Fund Manager?
- Compliance Bricks and Mortar for June 19
- I Ask For Your Money
- The SEC Goes After the Gate Keeper
- Whistleblower Retaliation
- Compliance Bricks and Mortar for June 12
Dodd-Frank’ed Real Estate
- Yes, the SEC Wants Real Estate Fund Managers to Register
- Are Real Estate Fund Managers Registered with the SEC?
- Are you an Investment Company?
- Real Estate Funds and the Investment Company Act
- Are you an Investment Adviser?
- Custody and Private Funds
- Private Equity Real Estate Top 50 – 2015 Edition of Who is Registered