It’s sad day in Boston. We’ve become accustomed to winning and the Super Bowl drought continues for at least another year. There were two compliance-related stories that came out of Super Bowl XLVI. The first was singer M.I.A.’s obscene gesture and expletive during the halftime show. After Janet Jackson’s nipple-gate incident eight years ago, you [...]
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Is a Mitt Romney Candidacy Good for Private Equity?
Mitt Romney puts his business background at the front of his campaign message. As the current front-runner for the Republican nomination, his background is going under increased scrutiny. Since his business background is in private equity, the industry should stop and wonder whether all of this publicity will be good or bad for private equity. [...]
US Private Equity Fund Compliance Companion
If you are looking for a good guide to help your private equity compliance program, PEI Media’s US Private Equity Fund Compliance Guide is a good place to start. There have been a few changes since its publication in 2010. PEI Media has just published the US Private Equity Fund Compliance Companion to provide an [...]
Compliance Bits and Pieces for December 23
Here are some recent compliance-related stories that caught my attention. The Saga of MF Global – Don’t Shoot the Messenger, Fire the Chief Compliance Officer by Tom Fox Both the DOJ minimum best practices and the amendment to the US Sentencing Guidelines, giving the CCO direct access to a company’s Board of Directors, would seem [...]
The Cost of Regulating Fund Managers and Investment Advisers
A group of organizations with Investment Adviser stakeholders engaged the Boston Consulting Group to conduct an economic analysis of IA oversight scenarios (.pdf) in the Securities and Exchange Commission’s study released in January 2011. The analysis came down solidly in favor of increased funding of the SEC as the solution for increased oversight of investment [...]
Compliance and the South Pole
We reckoned now that we were at the Pole. Of course, every one of us knew that we were not standing on the absolute spot; it would be an impossibility with the time and the instruments at our disposal to ascertain that exact spot. But we were so near it that the few miles which [...]
SEC Targeting Suspicious Investment Returns
Last week, the SEC announced THREE actions against investment advisers for compliance failures. The Securities and Exchange Commission has turned the dial a little higher and announced FOUR enforcement actions against multiple hedge funds by identifying abnormal investment performance. (Does their dial turn all the way up to 11?) The SEC launched an initiative to [...]
Compliance Officer Banned in the United Kingdom
As a compliance officer, I often find that many lessons come from enforcement actions. Those actions imposed on compliance officers are especially instructive. The latest to catch my attention comes from the United Kingdom. The Financial Services Authority levied a £14,000 fine and banned a compliance officer from performing any significant influence function in regulated [...]
Outsourcing Compliance and the CCO
One of the requirements of registration as a registered investment adviser is the appointment of a Chief Compliance Officer and the establishment of a formal compliance program. The SEC stated that a firm need not hire a new person to be the CCO. However, there will be a substantial time commitment. You can spread some [...]
Some New Financial Legislation is Moving Along
Four bills made their way through the Capital Markets and Government Sponsored Enterprises Subcommittee of the House Financial Services Committee. Private Company Flexibility and Growth Act (H.R. 2167) Access to Capital for Job Creators Act (H.R. 2940) Entrepreneur Access to Capital Act (H.R. 2930) The Small Company Job Growth and Regulatory Relief Act (H.R. ____) The Private [...]
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