They don’t examine investment advisers. Wyoming has long been on this list because it does not have a law regulating investment advisers. In Item 2 of Form ADV there was a box to check if your principal office and place of business was Wyoming. That kept you in SEC registration. The importance of whether a [...]
Tag Archives: New York
New York City Enacts New Rules for Its Pension Fund Investments
New York City Comptroller John C. Liu announced sweeping changes in the way New York City pension funds make investment decisions. Following the lead of New York state and several other states, New York City is changing how it deals with gifts, campaign contributions and placement agents. Ban on Campaign Contributions Comptroller Liu declines any [...]
Compliance Bits and Pieces
Here is this weeks collection of stuff I found interesting, but didn’t blog about: To Combat Overseas Bribery, Authorities Make It Personal Dionne Searcy for The Wall Street Journal “To really achieve the kind of deterrent effect we’re shooting for, you have to prosecute individuals,” Mark Mendelsohn, deputy chief of the Justice Department’s criminal division, [...]
Corporate Compliance Scam Continues. . .
. . But some of the perpetrators may have been caught. California California businesses have recent reports. The scam seems to have been operating in California for years. Colorado There are reports of the scam in Colorado: State Corporate Compliance fraud. The Secretary of State is also getting complaints about the Colorado Compliance Recorder: Updated [...]
You’re a Victim of a Ponzi Scheme, But What About Your State Taxes?
You missed the warning signs and got suckered into a Ponzi scheme. The IRS offered some tax relief for long-term Ponzi scheme investors (like some of the Madoff victims) who have paid taxes on gains from the investment. The IRS clarified the federal tax law governing the treatment of losses in Ponzi schemes. They also [...]
New Rules of the Game under the New York Public Pension Fund Reform Code of Conduct
Cleary Gottlieb put together a useful Alert Memo on The New Rules of the Game under the New York Public Pension Fund Reform Code of Conduct (.pdf) They outline the key provisions of the Reform Code and suggest action steps for investment firms that do business (or seek to do business) with New York Public [...]
New York Public Pension Fund Reform Code of Conduct
In a widely publicized story, The Carlyle Group has agreed to adopt New York Attorney General Andrew Cuomo’s Public Pension Fund Reform Code of Conduct. It is the first money manager to adopt Cuomo’s new “code of reform” for the municipal-pension market. (Carlyle executives will not be subject to any criminal liability under the settlement [...]
N.Y. Comptroller Bans Placement Agents for State Pension Fund
State Comptroller Thomas P. DiNapoli today announced he has banned the involvement of placement agents, paid intermediaries and registered lobbyists in investments with the New York State Common Retirement Fund (CRF). The ban includes entities “compensated on a flat fee, a contingent fee or any other basis.” See: N.Y. Comptroller Bans Placement Agents for State [...]
New York Public Pension Funds’ Regulation No. 85
The Superintendent of Insurance of the State of New York promulgated the Second amendment to Part 136 of Chapter IX of Title 11 of the Official Compilation of Codes, Rules and Regulations of the State of New York (Regulation No. 85) (.pdf) in October 0f 2008. The regulation is intended to have the business of [...]
Six States Now Require Social Security Number Protection Policies
Miriam Wugmeister, Nathan D. Taylor of Morrison & Foerester wrote the December Privacy and Data Security Update: Six States Now Require Social Security Number Protection Policies. Connecticut – Ct. H.B. 5658. Massachusetts – 201 Mass. Code Regs. §§ 17.01 – 17.04. Michigan – Mich. Comp. Laws § 445.84. New Mexico – N.M. Stat. §§ 57-12B-2 [...]
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