snow bricks

Compliance Bricks and Mortar for February 10

These are some of the compliance-related stories that recently caught my attention.   WHY SHOULD I GIVE A %$#@! ABOUT OVERSEAS BRIBERY? by Matt Kelly in the FCPA Blog This is on my mind thanks to a recent column in the legal blog Above the Law, “Is Trump the End of FCPA Enforcement?” The author, […]

Read full story · Comments { 0 }
trump

President Trump’s Two for One Regulatory Reduction Is Headed to Court

It seems like just a week ago that President Donald Trump signed an Executive Order requiring two regulations be repealed for every new one adopted.  It was. And this week a lawsuit has been filed challenging that executive order. The lawsuit was filed by Public Citizen, the Natural Resources Defense Council and the Communications Workers of […]

Read full story · Comments { 0 }
sec-seal

The Five Most Frequent Compliance Topics in SEC Exams

The SEC’s Office of Compliance Inspections and Examinations published a list of the five compliance topics most frequently identified in deficiency letters that were sent to SEC-registered investment advisers. The five are actually the bulk of advisor compliance requirements. It’s the examples in the five topics that are the most useful indicators. Compliance Rule Compliance […]

Read full story · Comments { 0 }
sec-seal

The SEC Is Making Room For A New Regulation

Although is questionable whether the Securities and Exchange Commission is subject to President Trump’s executive order calling for a reduction in the number of regulations, the SEC seems to be taking it to heart. Last week, Congress started the push to roll back the Extraction Disclosure Rule. This week, the SEC is looking to roll […]

Read full story · Comments { 0 }
img_5768

Comeback

It’s tough thinking about compliance this morning after staying up to watch the greatest comeback in Super Bowl history by one of the greatest quarterbacks, orchestrated by one of the greatest coaches. I reflect back humbly. I grew up with the red-uniformed Patsies. I remember the 1 and 2 win seasons. I remember the years […]

Read full story · Comments { 0 }
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 […]

Read full story · Comments { 2 }
gorsuch

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 […]

Read full story · Comments { 0 }
trump

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 […]

Read full story · Comments { 0 }
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 […]

Read full story · Comments { 2 }
bricks

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 […]

Read full story · Comments { 0 }