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Jedi Training and Compliance Training

As I was gently caressing my tickets for tonight’s early premier of Star War: The Force Awakens, another compliance thought came to mind. The Star Wars saga shows three examples of Jedi training. One of which falls far short of the compliance standard. We see glimpses of the younglings training at the Jedi Temple. That […]

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The Compliance Failure of the Death Star

The Death Star was touted as the “ultimate power in the universe.” But a few proton torpedoes managed to destroy the entire station. It didn’t make into the trilogy, but I assume there would have been an ensuing investigation that would have looked at the failures that lead to loss. At least I imagined there […]

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The Jedi and Compliance Failures

My family has been re-watching the Star Wars movies in anticipation of this week’s premiere of Episode VII. While watching Episodes I-III, I wondered if the Jedi could have used some compliance strategies to help prevent their downfall. Two of the goals of compliance are (1) to deter people in your organization from doing bad […]

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PRI finalizes ESG questionnaire

The Principles for Responsible Investment Initiative has launched the Limited Partners’ Responsible Investment Due Diligence Questionnaire to encourage standardized due diligence on environmental, social and governance considerations in private equity. The LP Responsible Investment DDQ was developed in consultation with a working group composed of 41 LPs, funds of funds and GPs. There are 21 […]

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Happy Hanukkah

How Hanukkah Came to the White House by Jonathan D. Sarna in The first president who took official notice of Hanukkah was one of the Jewish community’s least-favorite occupants of the White House, Jimmy Carter. In 1979, he ended 100 days of self-imposed seclusion over the Iran hostage crisis by walking to Lafayette Park, […]

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Dealing With Leftovers

If your Thanksgiving was anything like mine, you have leftover food. It’s a poor allocation of resources, but Thanksgiving has turned into a weekend of excess. Excess food, excess shopping, excess football, excess dessert, excess waistline. Perhaps your compliance program is also filled with leftovers. Very few compliance officers would say that they have more […]

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US Private Equity Fund Compliance Guide

If you are looking for something to read during the long Thanksgiving Weekend or a great holiday present, pick up a copy of the newly released The US Private Equity Fund Compliance Guide, Volume III. PEI Media just released this follow up that updates the original 2012 edition with the ongoing review and actions of […]

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The SEC Frowns Upon Outsourced CCOs

Apparently, the Securities and Exchange Commission was running a sweep of firms with outsourced CCOs. The Office of Compliance Inspections and Examinations “stopped by” 20 registered firms that outsourced their CCOs to third parties. The SEC published a new risk alert to let us know what they found. Surprisingly, the SEC did not paint a […]

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Net of Fees Performance Figures

Last year, the U.S. Securities and Exchange Commission looked at how many private equity firms calculate net of fees internal rates of return for their funds. The focus was on whether the performance figures disclosed if general partner investments are included in or excluded from that calculation. General partners in a private equity fund typically […]

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KC Royals and Compliance

Congratulations to the Kansas City Royals on winning the World Series. It was their first World Series in thirty years and a year after their heart-breaking loss in Game 7. Mrs. Compliance Building is from Kansas City and ecstatic about the club’s turnaround. The Mets faltered last night because of emotion. Starting pitcher Matt Harvey […]

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