FINRA’s Guide to the Internet

FINRA has published a Guide to the Internet for Registered Representatives. It paints a difficult picture for registered representatives wanting to use Web 2.0 tools. FINRA breaks internet activity into five main group for purposes or regulatory requirements: Publicly available Web sites (including banner advertisements, blogs and bulletin boards) are considered advertisements. An email or […]

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SEC Requirements for Online Annual Reports and Proxy Statements

The SEC is trying to move investors further into the internet era with its new regulations on the ability to furnish proxy materials to shareholders by posting them on an Internet Web site and providing shareholders with notice of the electronic availability of the proxy materials. [SEC Release 34-56135] This is amendment to the original […]

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Recent Changes to the ADA and FMLA

Goodwin Procter presented a webinar on recent changes to the Americans with Disability Act and the Family and Medical Leave Act. Rob Hale moderating the presentation. Heidi Goldstein Shepherd led off with a background on the ADA. The key concept for employers is that it is up to the employee to request a “reasonable accommodation” […]

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Why Don’t Sanctions Deter Fraud?

Meric Craig Bloch theorizes that punishing people who are caught committing fraud is not an effective way to deter fraud. The reasons behind his theory: Employees who commit fraud don’t anticipate getting caught. The threat of sanctions does not deter them because they don’t expect to face them. To deter them, you have to raise […]

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Is Your Organization Adequately Prepared to Fight Today’s Workplace Fraud?

EthicsPoint published this webinar focusing on proper and efficient investigations. The presenter was Meric Craig Bloch, VP Compliance and Corporate Investigations of Adecco Group North America. Meric predicted more fraud coming into the workplace as part of this down economy. Managers are focused on making their numbers and it is harder to do. Profile of […]

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California’s Pay-to-Play Laws

California requires disclosure of gifts to officials at public agencies. The disclosure is made using Form 801 (.pdf). This form is for use by all state and local government agencies to disclose payments made to the agency when the payments provide a personal benefit to an official of the agency. Examples may include travel, meals […]

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Colorado’s Pay-to-Play Law

The Colorado voters passed Amendment 54 in the November, 2008 elections, which amends the Colorado Consitution to limit campaign contributions: Text of the Proposed Initiative (.pdf) and Text of the Constitutional Amendment (.pdf). The consitutional amendment carries a presumption of impropriety between contributions to political campaigns and the award of sole source government contracts.

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West Virginia’s Pay-to-Play Law

West Virgina addresses pay-to-play abuse by limiting campaign contributions during the negotiation and performance of the contract. West Viginia Code §3-8-12(d) provides: (d) Except as provided in section eight of this article, no person entering into any contract with the State or its subdivisions, or any department or agency of the State, either for rendition […]

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Kentucky’s Pay-to-Play Law

Kentucky places limitation on campaign contributors who get no-bid contracts from the state.  K.R.S. §121.056(2) provides: No person who has contributed more than the maximum legal contribution established by KRS 121.150 in any one (1) election to a slate of candidates for Governor and Lieutenant Governor that is elected to office or any entity in […]

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Chart of Pay to Play Restrictions

Public Citizen has published a chart of the restrictions on campaign contributions from government contractors (.pdf)

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