Archive | Compliance Programs RSS feed for this section

Compliance Program Failure

The SEC slapped a fund manager and its out-sourced CCO. The main charge was engaging in undisclosed principal transactions. Beyond that obvious conflict issue, the order has some interesting statements about failures in the compliance program. Parallax Investments, LLC, a Houston based firm, registered with the SEC as investment adviser in 2010. It also had […]

Read full story · Comments { 0 }
compliance politics and money

Some Relief for a Fund Manager Under the Political Contributions Rule

SEC Rule 206(4)-5 for investment advisers and fund managers limits the ability of a firm’s employees to make political contributions. It’s a nasty rule. Violation of the rule does not require any bad intent. The breadth of affected political candidates is long, diverse, and hard to discover. Anthony Yoseloff worked at Davidson Kempner Capital Management […]

Read full story · Comments { 0 }

JOBS Act 2.0

It was an unusual show of bipartisan support when the original JOBS Act was passed in the Spring of 2012. Congress is following in the footsteps of movie studios and looking to produce a sequel. Financial Services Committee Chairman Jeb Hensarling has promoted a group of bills that he thinks will comprise the JOBS Act […]

Read full story · Comments { 0 }

The Monsters of Compliance – Monster Mash

I was working in the lab late one night When my eyes beheld an eerie sight For my monster from his slab began to rise And suddenly to my surprise He did the mash He did the monster mash The monster mash It was a graveyard smash He did the mash It caught on in […]

Read full story · Comments { 0 }

The Monsters of Compliance – Dracula

The pumpkins and garish Halloween decorations are out on my front lawn. With the Halloween season upon us, my mind has become stuck on movie monsters and been mixed with compliance. This is the terrible result. Vampires have taken many forms, mixing mythologies, weaknesses and desires. There is the regal version played by Bela Lugosi, […]

Read full story · Comments { 0 }

The Monsters of Compliance – Freddy Krueger

The pumpkins and garish Halloween decorations are out on my front lawn. With the Halloween season upon us, my mind has become stuck on movie monsters and been mixed with compliance. This is the terrible result. Freddy Krueger terrorizes the kids of Springwood, Ohio, attacking them when they sleep. He seeks revenge for the dark […]

Read full story · Comments { 0 }

The Monsters of Compliance – The Mummy

Ignore the warning at your peril. The archaeologists were told to be careful with the Imhotep’s mummy. He had been punished for trying to resurrect his forbidden lover. In the 1932 version, Boris Karloff’s Imhotep was mummified alive for his crime. The archaeologists had been warned not to read the Scroll of Thoth. It brought […]

Read full story · Comments { 0 }

Monsters of Compliance – Werewolf

The pumpkins and garish Halloween decorations are out on my front lawn. With the Halloween season upon us, my mind has become stuck on movie monsters and been mixed with compliance. This is the terrible result. The werewolf is old and widespread legend. Lycanthropes gain the ability to turn from human form into a wolf […]

Read full story · Comments { 0 }

The Monsters of Compliance – Frankenstein’s Monster

The pumpkins and garish Halloween decorations are out on my front lawn. With the Halloween season upon us, my mind has become stuck on movie monsters and been mixed with compliance. This is the terrible result. Victor Frankenstein builds a creature in his laboratory with a mixture of surgery, chemistry, and alchemy. His creation horrifies […]

Read full story · Comments { 0 }

The Monsters of Compliance – Zombies

I finally grabbed some pumpkins and put some garish Halloween decorations on my front lawn. My mind has become stuck on movie monsters and been mixed with compliance. This is the terrible result. What happens when the dead won’t die? The zombie apocalypse. Zombies in pop culture can be traced back to George Romero’s The […]

Read full story · Comments { 0 }