Compliance Programs
The Trouble with Anonymous Surveys
So how are your surveys working? Do you get meaningful results? Are the results skewed by those who responded (versus those who… » Read More
Criminal Provisions under Dodd-Frank
When thinking designing compliance programs, I pay extra attention to the issues that can result in jail time. It’s one thing to pay a fine, it’s a much bigger problem when you take someone’s freedom away. The Dodd-Frank Wall Street Reform & Consumer Protection Act has added several new federal criminal offenses. The National Association… » Read More
Compliance Bits and Pieces: Mark Hurd Special
Last Friday, the big news in compliance was the sudden resignation of Mark Hurd as the CEO and Chairman of the Board of Hewlett-Packard. I decided to put together a compilation of other stories I found interesting. HP and me: Coincidence or not? by Michelle Leder in Footnoted Of course, footnoted had done its own… » Read More
Be the Mayor, not the Sheriff
Are you getting in the way or helping to move your organization forward? Inevitably, compliance professional will need to step in and stop an activity or start a discipline process for someone who broke the rules. That does not have to be the primary focus of the your job, or the compliance profession. Frank Sheeder,… » Read More
That’s a $h!#ty Policy
On the front page of today’s Wall Street Journal is story about one of the fallouts from Goldman Sachs’ recent problems with the SEC: George Carlin Never Would’ve Cut It at the New Goldman Sachs. One of the most sensational bits of Goldman Sachs fiasco was an email from a Goldman executive “[B]oy that, timberwolf… » Read More
Do Prosecutions Stop Insider Trading?
We generally assume that the prosecution of crime acts as a deterrence to others who may think about committing the crime. One of the key factors in fraud is opportunity. If the wrongdoer thinks they can not get away with the violation, they are less likely to commit the violation. At least that is the… » Read More
Compliance Bits and Pieces – July 2
Early this week, some people expected fireworks to come from the Free Enterprise v. PCAOB decision. Instead, we got cheap package of sparklers. Fun for a few minutes, but unlikely to leave much of a lasting impression. Here are some interesting compliance-related stories from the past week. SEC Statement on Supreme Court’s Decision in FEF… » Read More
Cheap Sunglasses and Compliance
Can cheap sunglasses affect your ethical behavior? An important part of a compliance program is monitoring and improving the ethical behavior of your workforce. I’m always intrigued by ethics experiments. Francesca Gino of Chapel Hill, Michael Norton of Harvard Business School, and Dan Ariely of Duke tested the effect of wearing knock-off designer sunglasses. They… » Read More
Should Private Funds Have more than $10 Billion?
The current draft of the Dodd-Frank Wall Street Reform and Consumer Protection Act has a surprise in it for big hedge funds. By “surprise” I mean tax. Title XVI: Financial Crisis Special Assessment has a $19 billion fee ready to be assessed against financial companies institutions with more than $50 billion in assets and hedge… » Read More
Final Text of the Private Fund Investment Advisers Registration Act of 2010
There is a lot happening in the Dodd-Frank Wall Street Reform and Consumer Protection Act. (Yes, that appears to be the agreed upon name of the financial reform bill.) I’m most interested in its Title IV: Private Fund Investment Advisers Registration Act of 2010. The act will remove the current exemption from SEC registration for… » Read More
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Compliance Building is published by Doug Cornelius, focusing on compliance and ethical issues for private equity real estate companies. Read more in About.
