What Now? Trump Presidency and Compliance

While votes are still being counted, it’s clear that the Clinton Firewall in Michigan and Wisconsin did not hold. Get used to saying “President Trump.” The other story is that Republicans held the Senate, leaving Congress in the hands of the Mitch McConnell and Paul Ryan. That means some aspect of the Republican platform will […]

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An election cycle that has been dragging on for ever is almost over. If you have not yet voted, be an informed voter. I urge to look at the issues. Try using to see which candidate best aligns with your positions on the issues. Then line up and cast your vote. I took advantage […]

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Privcap – Game Change Real Estate 2016

What better way to spend November 2 than in Chicago with the enthusiasm of the Cubs winning game 6 the night before the conference and the historic World Series win that night. I was in the windy city for Privcap Game Change conference for real estate in 2016. The conference was largely focused on real […]

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SEC Clears the Way For Intra-State Crowdfunding

Most states have passed crowdfunding laws. One of the barriers has been the breadth of the federal preemption of interstate securities transactions. To be intra-state, and therefore out of the jurisdiction of the Securities and Exchange Commission, the investors and the company doing the fundraising needed to all be in the same state. The problem is […]

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CCO Needs To Be a Jack of All Trades

Andrew Donahue, the Chief of Staff of the Securities and Exchange Commission gave a speech earlier this month to the National Society of Compliance Professionals National Conference. He was attempting to share his thoughts on the current and future challenges that compliance professionals in the financial services area face. He envisions that CCOs will need […]

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Co-Investments and the SEC

Last year, regulators from the Securities and Exchange Commission raised concern about co-investments. The statements were vague about what was bothering the regulators. Co-investments allow a private equity to lower its exposure to an investment and give others an opportunity to invest along side the fund at a discounted rate. It can be an opportunity to […]

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When Does A Stock Picking Contest Turn Into a Derivative

Forcerank’s premise was simple: “fantasy sports for stocks”. Forcerank runs mobile phone games where players predict the order in which stocks would perform relative to each other.  In its original form, if a player did well he or she won points and could some receive a cash prize. Forcerank kept 10 percent of the entry […]

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The SEC’s Pay-to-Play Rule and California Labor Law

Keith Bishop chimed in on Campaign Contributions and the SEC in the context of California law: Pay-To-Play Meets The California Labor Code at the California Corporate & Securities Law blog. He point to  California Labor Code: Section 1101. No employer shall make, adopt, or enforce any rule, regulation, or policy: (a) Forbidding or preventing employees from […]

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Post Debate Campaign Contributions and the SEC

With the first of the presidential debates over, I thought it would be a good time to refresh myself on the SEC’s limits on political campaign donations by investment advisers. SEC Rule 206(4)-5 was put in place to limit political influence on government pension plan investment choices. Under the rule: 1. All political campaign contributions should be […]

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Personal Benefit in Insider Trading

While Mr. Cooperman was accused of making millions on insider trading. Sheren Tsai made $23,914.41 on her illegal trades. The relatively small amount of the gains caught my eye in the press release, but a particular line in the pleadings made me think it was worth highlighting. Ms. Tsai was (is?) in a romantic relationship […]

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