Compliance Bricks & Mortar for November 10

These are some of the compliance-related stories in my reading list.

Your General Counsel is Your CECO? Really? by Joseph E. Murphy

There continues to be controversy about whether a company’s general counsel should also be the CECO, especially at large companies. Putting aside the question of whether this is a good idea, however, I want to pose a different question for companies that claim their GC is also the CECO: Could you prove it? [More…]

Governance and Transparency at the Commission and in Our Markets by SEC Chairman Jay Clayton

The next near-term agenda, which will be published as part of the federal government’s Unified Agenda in coming months, will be shorter than in the recent past. This change is rooted in a commitment to increase transparency and accountability. Some may question the prioritization reflected in the near-term agenda. They have a right to do so, and we welcome constructive comments. We should endeavor to be transparent to Congress, investors, issuers, and other interested parties about what rules we intend to pursue and have a reasonable expectation of completing over the coming year. And then, we must set forth to do it. [More…]

SEC Warns Investors About Paid-to-Click Scams

The Securities and Exchange Commission is warning investors to beware online “paid-to-click” scams that promise an easy payday by merely purchasing a membership or an advertising product up front and then clicking on a certain number of online ads each day. The SEC’s investor alert explains that these online advertising programs may have little to no revenues besides membership fees or sales of “ad packs” and may be nothing more than a Ponzi scheme. [More…]

California SB 396: New Law Requires Anti-Harassment Training to Cover Gender Identity and Sexual Orientation

The new law applies to organizations with 50 or more employees, and amends the existing sexual harassment training for managers and supervisors, as required by the California Department of Fair Employment and Housing (DFEH). SB 396 also requires employers to display a poster developed by the DFEH on transgender rights in the workplace. The existing California laws covering sexual harassment training are California AB 1825 and California AB 2053.  [More…]

DOJ Penalty Policy Under Review by Matt Kelly in Radical Compliance

The Justice Department is reconsidering how it imposes monetary penalties for corporate misconduct, so that parallel investigations happening with other regulators don’t pile on the pain unnecessarily, the deputy attorney general said Wednesday.

Deputy AG Rod Rosenstein made those remarks during a wide-ranging speech in New York. He also said he hopes to avoid putting policy changes into a “Rosenstein Memo,” and still stressed the importance of companies cooperating with the Justice Department when misconduct is under scrutiny. [More…]

Compliance Building has been quiet this week. It’s for sad reasons. One of my dogs died earlier this week.

Guinness was 200 pounds of joy and enthusiasm, who rarely realized that he was so enormous. We knew when we rescued him, that it would be a roller-coaster to integrate him into our family. But it was a joyous few years.

Great Danes are not known for having long life spans. But his was cut short unexpectedly after developing some heart troubles. I miss his giant head, his table destroying tail and his enormous personality.