Swine Flu, Disaster Recovery, and Compliance

One aspect of a compliance program is disaster recovery. Investors want to know that your operations can be up and running if something goes wrong. Although first thoughts go to an extraordinary event like the World Trade Center attacks, the problem is more likely to be something less dramatic. From today’s headlines, it may be […]

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danger sign

Moral Hazard and Structural Compliance

I have been tossing around the concept of structural compliance in my head. The idea is to focus on the alignment of employee incentives with the long term goals of the organization. Jeff Kaplan forwarded me an article he wrote for the April 2009 issue of CCH’s Federal Ethics Report: Boards of Directors, Moral Hazard […]

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Weekend Book Review – The Nine

You would  expect a book about the inner workings of the United States Supreme Court to be dry and boring. I did, which is why this book has been sitting unread in my book pile for months. Surprise! I found this book to be very interesting and entertaining. The Nine: Inside the Secret World of […]

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Coming Attractions – Frontline Reports on Madoff

Next month, Frontline is running a report about Bernard Madoff on a PBS station near you. The episode premiers the week of May 12. “Bernard Madoff’s success as a broker made the competition wonder how the man could produce such steady returns in good times and bad. The SEC investigated several times over the last […]

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Boston from the Charles

Corresponding with Cornelius

Here are some of my recent comments on some other blogs or other websites that allow comments. Part of the new changes in the internet is the ability for readers to engage writers and other readers of their stories. I am happy to have you leave comments at Compliance Building. But if not here, take […]

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Failure to Conduct Diligence Can Lead to SEC Sanctions

If you advertise that you have due diligence process, you had better follow that process. The Securities and Exchange Commission brought an administrative proceeding against an investment adviser for failing to follow its advertised due diligence program. The Hennessee Group promoted its process for evaluating and selecting hedge funds as the “Five Level Due Diligence […]

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Credit Rating Agency Reform

Last week the Securities and Exchange Commission held a roundtable on the credit agencies to consider a range of ideas to get tougher on them. Securities and Exchange Commission Chairman Mary Schapiro lead the discussion and pointed out that “rating agency performance in the area of mortgage-backed securities backed by residential subprime loans, and the […]

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N.Y. Comptroller Bans Placement Agents for State Pension Fund

State Comptroller Thomas P. DiNapoli today announced he has banned the involvement of placement agents, paid intermediaries and registered lobbyists in investments with the New York State Common Retirement Fund (CRF). The ban includes entities “compensated on a flat fee, a contingent fee or any other basis.” See: N.Y. Comptroller Bans Placement Agents for State […]

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Earth Day

Today is the 39th celebration of Earth Day, celebrated in the U.S. each April 22 since 1970. Senator Gaylord Nelson from Wisconsin called for an environmental teach-in, or Earth Day, to be held on April 22, 1970. In that same year, the Environmental Protection Agency was formed to consolidate federal research, monitoring, and enforcement. About […]

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SIGTARP Quarterly Report

Congress was smart enough to not let loose the billions of TARP funds without some oversight. The Office of the Special Inspector General for the Troubled Asset Relief Program (SIGTARP) was established by Section 121 of the Emergency Economic Stabilization Act as amended by the Special Inspector General for the Troubled Asset Relief Program Act […]

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