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Compliance Bricks and Mortar for August 7

I finished the charity bike ride across Massachusetts. There’s still time to donate. Look at the bottom of this update. Since, I’m off the bike, these are some of the compliance-related stories that recently caught my attention. SEC Tries Flipping Witnesses by Jean Eaglesham in the Wall Street Journal The SEC touts the cooperation program […]

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Dodd-Frank Act Compliance Cost for Private Funds

Are Dodd-Frank Act compliance costs forcing smaller private investment fund advisers out of the market? Wulf Kaal, Associate Professor at the University of St. Thomas School of Law, decided to take a look at the data and see. It should come to no surprise that the answer is likely: yes. The analysis in this paper […]

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Compliance Bricks and Mortar – Pan-Mass Challenge Edition

At the time this story gets published on Friday, I will be on bike somewhere between Hillsdale, New York and Sturbridge, Massachusetts. That’s the first leg of my Pan-Mass Challenge ride to support cancer research. I’ll end up in Provincetown on Sunday afternoon. Many of the readers of Compliance Building have generously supported my ride. […]

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Pay to Play Rule In Effect on July 31

The Securities and Exchange Commission announced the compliance date for the ban on third-party solicitation pursuant to the Pay-to-Play rule: July 31, 2015. Rule 206(4)-5 prohibits an investment adviser from providing compensated services to a government entity, following a political contribution to certain officials of that entity. Rule 206(4)-5 became effective on September 13, 2010 […]

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Compliance Bricks and Mortar for July 24

These are some of the compliance-related stories that recently caught my attention in between bike rides.(It’s not too late to support my Pan-Mass Challenge ride to support cancer research.) SEC hires new private funds specialist by Katherine Bucaccio in Private Funds Manangement Jennifer Duggins will join the commission later this month to co-head OCIE’s Private […]

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SEC Meet and Greet – Part 2

Last week I was able to share with you the introductory letter from a firm that recently registered with the Securities and Exchange Commission and quickly received a meet and greet request. That same reader was nice enough to share his experience with me and the readers of Compliance Building. The SEC had a four […]

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Compliance Bricks and Mortar for July 17

These are some of the compliance related stories that recently caught my attention. Deflategate (Part Two): My texts runneth over by Joshua C. Garbarino in The FCPA Blog The spontaneous nature of texts, often with photos, and sending them before anyone thinks about the consequences, means the texts can be a very revealing source of […]

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BE-10 Survey Requirements: What Private Equity Funds Need to Know

Under the International Investment and Trade in Services Survey Act of 1977, the U.S. Bureau of Economic Analysis in the Department of Commerce conducts a “benchmark survey” of U.S. direct investment abroad every five years. U.S.-based companies with ownership of “foreign affiliates” are required by law to participate in the survey by completing and submitting a […]

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SEC Meet and Greet

The Securities and Exchange Commission tackled a large group of new advisers, Post-Dodd-Frank, with the Presence Exam initiative. Then tackled a backlog of exams with the never-before examined initiative. The SEC stated that it wanted to start reaching out to advisers soon after they register to get on top of things from the onset. A […]

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Compliance, Cycling and the Tour de France

For me, July starts with the red, white and blue, then quickly turns to yellow. The yellow jersey worn by the overall leader of the Tour de France.   I’ve been a big fan of the Tour de France for the past decade and a half. I admit that it was the success of Lance […]

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