lights out

Weekend Reading: Lights Out

Should we worry about an attack on the Untied States’ electrical infrastructure? Ted Koppel says “very much so” in his book: Lights Out. You probably better know Mr. Koppel as the longtime anchorman on ABC News and Nightline. In Lights Out he puts on his old school journalist hat and puts together an in depth […]

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Compliance Bricks and Mortar for January 22

These are some of the compliance related stories that recently caught my attention. Corporate Disclosure, Social Policy, and Dirty Pool by Matt Kelly in Radical Compliance [L]et’s use the Conflict Minerals Rule as the flagship example of a much broader bad idea in Dodd-Frank—using federal securities law to force social policy on corporations. Because as […]

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Could Whistleblowing Be The New Short-Selling?

The Securities and Exchange Commission made an unusual announcement this week, announcing a whistleblower award to a company outsider. Could this been a new way to profit from companies engaged in fraud? Is this a new alternative to short selling? Earlier this week, the SEC announced a $700,000 award to a company outsider who conducted […]

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Custody Rule Gotcha on PCAOB “Registered and Subject to Regular Inspection”

A friend in the private fund compliance community just came up with another “gotcha” under the Custody Rule. His client used an auditor that was registered with PCAOB, but had not yet been inspected. He thought it was enough to be registered, while waiting for an inspection. An SEC examiner argued that the auditor needed […]

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Another Pay-to-Play Case

There are few among us who think the high cost of getting elected and fundraising that it requires is good for American politics. The SEC took a moral high ground and passed Rule 206(4)-5. That rule effectively prohibits investment managers from making political contributions to politicians who control pension money, other than small token amounts. […]

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Jeff Levine

Saying Goodbye To An Old Friend

The world got a little less interesting now that this big, bold, brash guy has left it. I have not posted in Compliance Building while I’ve been trying to deal with this loss. My best friend, Jeff Levine, was diagnosed with cancer just before Thanksgiving. He lost his battle against the disease last week. Jeff […]

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Going All In To Save The Fund

In browsing through enforcement actions I look for lessons learned. In some cases it’s compliance doing its job and stopping a fraud before it gets too big. The case against Owen Li caught my eye. His trades were not working so he made a last ditch effort to make it all back. Given that this […]

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Happy Start to Your Compliance New Year

I hope you were able to enjoy the long weekend. Perhaps an extra long weekend if you found December 31 to be an optional work day. Today is obviously not the first day of the new year, but it is the first day of work in the new year. With the new year, come the […]

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Happy New Year 2016

Compliance Bricks and Mortar for the New Year

Happy New Year! May 2016 be better for you than 2015. These are some of the compliance related stories that caught my eye before the end of 2015. Compliance Fiction by Roy Snell in SCCE’s Compliance & Ethics Blog Let me tell you a completely fabricated compliance story. [More…] The Father of Texas and Leadership […]

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Happy End of 2015

Whether 2015 was a great year or a terrible year for you, I hope that 2016 will be a better year. I hope that some of the stories I published this past year were useful. Be compliant in 2016  

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