Doug Cornelius on compliance for private equity real estate
While I was preparing for Thanksgiving on Wednesday, the Securities and Exchange Commission put 43 of its rules on the chopping block. As you know, it’s not so simple to just eliminate a rule. Eliminating a rule is itself a rulemaking, requiring notice and comment periods. Of course, the SEC would also need to justify … Read more »
Thank you for taking the time to read Compliance Building. I’m grateful to meet, chat and correspond with so many of you in the compliance community. I hope you get to enjoy a long weekend to reflect and spend time, with friends, family, neighbors and loved-ones. Read more »
The Financial Crimes Enforcement Network announced the issuance of revised Geographic Targeting Orders. The threshold for reporting has been reduced down to $300,000 for all-cash purchases of residential real estate. The geographic scope has been expanded to now include nine cities: Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; … Read more »
These are some of the compliance-related stories that recently caught my attention. Little bits to grow your building knowledge base. Steve Cohen Will Pay Extra for Compliance Tips by Matt Levine How did this happen, you might well ask. There are some obvious answers. For one thing, a culture of compliance at Point72 really might … Read more »
The SEC’s Office of Compliance Inspections and Examinations has issued a risk alert announcing its intention to conduct a series of examination initiatives focused on issues affecting certain registered investment companies and investment advisers. According to the Risk Alert, examiners have six initiatives: Index funds that track custom-built indexes Smaller ETFs and/or ETFs with little secondary … Read more »
Stan Lee, the legendary writer and publisher of Marvel comics who helped created countless superheroes, has died. He was 95. On his own and through his work with collaborators Jack Kirby, Steve Ditko, Bill Everett. and others, Mr. Lee created Spider-Man, the X-Men, the Mighty Thor, Black Panther, Iron Man, the Fantastic Four, the Incredible Hulk, … Read more »
Crypto Currency can be a Commodity A federal judge in Massachusetts agreed with the Commodity Futures Trading Commission’s view that virtual currencies are commodities under the Commodity Exchange Act and subject to federal regulation. See CFTC v. My Big Coin Pay, Inc., (D. Mass. Sept. 26, 2018). The CFTC sued a virtual currency company and several … Read more »
These are some of the other compliance-related stories that recently caught my attention. Time to Renew Registrations for RIAs and BDs; SEC Allows Mutual Fund Boards to Rely on CCOs, and NFA kicks out Members for Failure to Pay Dues: Regulatory Update for November 1, 2018 by Hardin Compliance Consulting LLC Annual Renewal Program for … Read more »
The Securities and Exchange Commission has the same problem as any compliance professional: “How do you prove you’re being effective?” The Enforcement Division issued its annual report of its ongoing efforts to protect investors and market integrity. On one hand, remedying the identified harms committed by bad actors on investors is easy to measure. The missing piece is … Read more »
The Securities and Exchange Commission says “no.” My first question is what is a mutual water water company? From my view here in New England water comes from the municipality or your own well. California is big and creating whole new communities. In this case, the Tesoro Viejo Master Mutual Water Company is being formed … Read more »