oil well and compliance

Congress Disapproving The SEC Rule That Congress Made The SEC Make

Dodd-Frank made the Securities and Exchange Commission create a rule on the disclosure of payments by resource extraction issuers. The SEC finally got the rule out this fall. Now Congress is threatening to abolish the rule. Section 1504 of the Dodd-Frank Act directed the Securities and Exchange Commission to “issue final rules that require each […]

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The New Supreme Court Pick and Private Funds

Justice Scalia died last year and replacing his position has been held up by partisan politics ever since. President Trump has made his pick, federal appeals court judge Neil Gorsuch from the 10th Circuit, and the confirmation battle has begun. Being very liberal on social issues, I’m disappointed that the Senate chose not consider President […]

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Add One, Take Two Away

Prior to his inauguration, President Trump promised a 75% reduction in regulations. I was left scratching my head about what he meant. Did he want the Code of Federal Regulation to be 75% shorter? How do you decide where one regulation begins and another starts? What about statutes enacted by Congress that specifically mandate the […]

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trump[ pence

The Trump Organization’s Compliance Program Begins

Last week, the Trump Organization kicked off its compliance program by making two appointments. Bobby Burchfield will be independent ethics adviser. He’ll be responsible for signing off on transactions that could raise ethics or conflicts of interest concerns. George Sorial will become chief compliance counsel. In the January 11 press conference, Sheri Dillon announced: [T]o […]

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Compliance Bricks and Mortar for January 27

These are some of the compliance related stories that recently caught my attention. Trump Gets Subtle Pre-taliation Warning by Matt Kelly in Radical Compliance On Wednesday the Office of Special Counsel issued a reminder that any policies about communications from government employees—like, say, telling them to stop talking about climate change; or to stop talking entirely—must […]

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sec fraud

CCO Liability for False Statements on Form ADV

Susan Diamond was Chief Compliance Officer of Saddle River Advisors. Now, Ms. Diamond is out of pocket for a $15,000 penalty and is subject to a nine-month suspension from being associated with any investment adviser or other financial services firms. After the suspension, she will be prohibited from acting in the securities industry in certain managerial […]

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ia watch ia week

Red Hot SEC Exam Topics

IA Watch presented a webinar: Red Hot SEC Exams Topics in 2017, Plus Exam-Prep Steps from Peers Who’ve Survived Recent Exams. The presenters were Fred Shaw, Principal/Director of Compliance, Hamilton Lane Adam Reback, CCO, J. Goldman & Co Chuck Daly, Principal, Constellation Advisers Michelle Martin, CCO, Longfellow Investment Management These are my notes: Even though there […]

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Conflicts Ahead – What Can We Learn From the Early Days of the Trump Administration

President Trump has come into office as the first president in modern era to own an active business empire. One in which his name is the probably the most valuable asset. Like him or not; voted for him or not; He is the President. As we have seen in the past, scandals limit the ability […]

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Compliance Bricks and Mortar for January 20

These are some of the compliance related stories that recently caught my attention. Experts Ponder Role of Trump Organization Compliance Counsel by SAMUEL RUBENFELD in WSJ.com’s Risk & Compliance Journal As compliance counsel, the person’s ethical obligation will be to the organization, not to the president, making the role less robust than retaining an independent […]

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The SEC Really Means It About Pretaliation Severance Agreements

In case you were not clear that the Securities and Exchange Commission is serious about enforcing Rule 21F-17, BlackRock is the latest to run the perp walk. The SEC accused the money management giant of improperly using separation agreements that forced employees to waive their ability to obtain whistleblower awards. The SEC adopted Rule 21F-17, which provides in […]

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