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75th anniversary

75th Anniversary Celebration: Investment Company and Investment Advisers Acts

The SEC is hosting a conference Tuesday, September 29 to commemorate the 75th Anniversary of the Investment Company Act and the Investment Advisers Act.  The event will include remarks from SEC Chair Mary Jo White and fellow commissioners, as well as a series of panel discussions featuring industry pioneers, former SEC chairmen and division directors, […]

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The SEC’s Cybersecurity Smackdown

Last week the Securities and Exchange Commission issued a new risk alert on cybersecurity and this week the SEC announced a new action for a cybersecurity breach. The action is just as bad as I thought it could be. It also shows that the SEC is misplaced in being a cybersecurity enforcer. R.T. Jones Capital […]

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Cybersecurity Exams Part II: More Governance

Last year, the Securities and Exchange Commission raised a cloud of concern when it started its cybersecurity initiative aimed at broker/dealers, investment advisers and fund managers. Based on an interview in April it seems that initiative would continue into a phase 2. The SEC recently released its OCIE’s 2015 Cybersecurity Examination Initiative. According to the […]

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Riverfront relaxtion

Vacation Reset For Your Compliance Program

Many of you, like me, are back from vacation or a Labor Day barbecue. I’m still washing sand out of my shoes and rubbing aloe on my skin that was in the sun too long. After being away from the office, my email box is filled with messages that should be returned, issues that need […]

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citizen vc

On line portals for fundraising

As part of the updates on private placements, the Securities and Exchange Commission granted a no-action letter to Citizen VC, an online venture capital firm. The main question was whether the firm was creating “substantive, pre-existing relationships” with prospective investors through its website. The firm wanted to avoid a result that its offers & sales […]

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Newspaper page with eraser of erasing news, vector Eps10 image.

A Win for Compliance Officers

Judy Wolf did a bad thing. During an insider trading investigation she fudged some documents. The Securities and Exchange Commission investigated the insider trading matter and Ms. Wolf’s log of her review. The fudging was discovered. She was fired and the SEC brought an enforcement against her. There is some good news from that bad […]

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Dodd-Frank Act Compliance Cost for Private Funds

Are Dodd-Frank Act compliance costs forcing smaller private investment fund advisers out of the market? Wulf Kaal, Associate Professor at the University of St. Thomas School of Law, decided to take a look at the data and see. It should come to no surprise that the answer is likely: yes. The analysis in this paper […]

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Series with an Anonymous African-American politician in front of United States flag.  A variety of concepts and props, including healthcare, education, wealth and poverty.

Pay to Play Rule In Effect on July 31

The Securities and Exchange Commission announced the compliance date for the ban on third-party solicitation pursuant to the Pay-to-Play rule: July 31, 2015. Rule 206(4)-5 prohibits an investment adviser from providing compensated services to a government entity, following a political contribution to certain officials of that entity. Rule 206(4)-5 became effective on September 13, 2010 […]

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Compliance, Cycling and the Tour de France

For me, July starts with the red, white and blue, then quickly turns to yellow. The yellow jersey worn by the overall leader of the Tour de France.   I’ve been a big fan of the Tour de France for the past decade and a half. I admit that it was the success of Lance […]

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A History of the World in Sixteen Shipwrecks

Weekend Reading: A History of the World in Sixteen Shipwrecks

Shipwrecks are tragic, but have been a part of human history since we started making ships. There are an estimated three million ships sitting on the bottom of the oceans, seas, lakes, and rivers of the world. Of that staggering number, Stewart Gordon picked sixteen to tell the story of human history. A History of […]

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