Category: Compliance Programs

Stick The Landing

I saw this picture and it made think about compliance. At its most basic, the plane did land, the aviators did not die, and the aircraft carrier is still floating. But it was a not a compliant landing. The plane, the aircraft carrier, and the pilot are all damaged to some extent. That it was

CCO Liability: What Risks Remain and What You Can Do to Minimize Them

IA Watch produced an informative webinar on CCO Liability. These are my notes. Carl Ayers (Moderator)  Publisher, Regulatory Compliance Watch Brian Moran, Executive director and CCO Sterling Capital Management Joseph McGill, J.D., Chief Compliance Officer Lord, Abbett & Co. Kelley Howes, Counsel Morrison Foerster Heidi Vonderheide of Ulmer & Berne LLP First up was Heidi. Her

Froome, Teamwork and Success

Professional cycling is not a mainstream sport in the U.S., so I would guess that few reading this story share my love of the Tour de France. (With the notable exception of Tom Fox.) The race has several different competitions going at the same time, with a confusing mix of skinny guys, tarted up with

Compliance Bricks and Mortar for June 30

These are some of the compliance-related stories that recently caught my attention. SEC’s Clayton Vows to Do More Exams with Less Funding in AdvisorHub SEC Chairman Jay Clayton testified to Congress on Tuesday morning that the agency will increase its examinations of investment advisers by 20% in the current fiscal year and nudge the numbers

We Have Seen The Enemy And It Is US

There was a massive cyberattack over the weekend that has afflicted 200,000 computers in more than 150 countries. The malware locks users out of their computers and threatens to destroy data if a ransom is not paid. It turns out that the the malicious software used in the cyberattack was originally been developed by the

Comey and Compliance

The firing of FBI Director has set off a firestorm. Obviously, there is a great deal of partisan tilt to the action. I wanted to focus on the lesson we can see from a compliance perspective. It is an example of the need for independence of compliance and investigations. President Trump fired someone who was

Broker Dealer Private Fund

It was four years ago that David Blass mentioned that the SEC was taking a closer look at broker-dealer requirements for private fund managers in two contexts: selling interests in the funds and earning fees from the fund for capital transactions. Part of the problem is that the safe-harbors for selling your fund interests is

The Overbooking Failure

Air travel has gotten has gotten less pleasant over the years. The TSA makes it unpleasant to get to the plane. Then the plane themselves have reduced passenger room. United took the unpleasantness to an even lower level when it forcibly removed a passenger from an overbooked flight. “Flight 3411 from Chicago to Louisville was

The Fearless Girl

The sculpture, titled “The Fearless Girl,” was made by Kristen Visbal and photographed by Federica Valabrega. State Street Global Advisors conspired in the middle of the night to drop a statue in Bowling Green Park of a girl facing off against the famous Wall Street Charging Bull. It’s part of a campaign by SSGA to

Can Compliance Be Cool?

John Glenn passed away at the end of 2016. He was a Senator, an astronaut, and distinguished pilot in the World War II and the Korean War. The picture below struck me as one of ultimate cool. Mr. Glenn had just finished orbiting the Earth on February 20, 1962. Doing so in a tin can