Doug Cornelius on compliance for private equity real estate
JP Morgan paid $2 billion in fines and disgorgement for failing to file a suspicious activity report against Bernie Madoff. I provided my two cents. Here are some other views. The invincible JP Morgan by Felix Salmon This is sheer unmitigated — and, yes, probably criminal — incompetence. It takes a very special kind of … Read more »
Yesterday J.P. Morgan agreed to forfeit $1.7 billion for its failure related to the Bernie Madoff fraud, plus several hundred million in fines. As part its deferred prosecution agreement, the bank agreed that it did not have the proper systems in place to catch Madoff. It’s easy to target the bank for compliance failures but … Read more »
My goal this year was to finish reading a book every other week. (For the math or calendar challenged, that’s a goal of 26 books.) I’m happy to say that I smashed through that goal. I ended up with 44 books on my Read in 2013 shelf during the year. Compliance Books For those of … Read more »
One of my favorite books of 2012 was Charles Duhigg’s The Power of Habit. The book is full of interesting ideas and based on an impressive collection of research. But it does a great job of balancing intellectual seriousness with practical advice. Even better, it’s written in a lively style, making it easy to read … Read more »
The Securities and Exchange Commission issued an order against Mark M. Wayne, the president, Chief Executive Officer, and Chief Compliance Officer of Freedom One Investment Advisors, Inc. for violations of the the custody rule under the Investment Advisers Act. Although that’s the headline, the SEC action shows many other compliance failures. First, the custody issues. … Read more »
On behalf of the entire staff of Compliance Building we wish you a very happy holiday season, a merry Christmas, and a compliant new year. Christopher Columbus Park by Igor Motov CC NC BY SA Read more »
Title IV of the Jumpstart Our Business Startup (JOBS) Act mandated changes to the moribund Regulation A offering process. That law raised the bar from $5 million to $50 million and prodded the SEC into making changes. The SEC issued the proposed rule with enough interesting treats that it may be worth exploring. The SEC … Read more »
These are some of the compliance-related stories that recently caught my attention. SEC Enforcement Statistics: A Work in Progress? by Thomas O. Gorman in SEC Actions The SEC released Enforcement Division statistics for government Fiscal Year 2013 along with a table and chart listing the number of actions filed each year as well as the … Read more »
Five regulatory agencies adopted the final rules that implement the Volcker Rule, a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act. It’s a big, complicated, ugly rule that will drive compliance officers at banks crazy trying to implement. Have fun reading all 964 pages. The text of the regulations themselves only run … Read more »
There is a new requirement for Investment Advisers Representatives in Massachusetts. Beginning on January 1, 2014 each applicant for registration as an investment adviser representative in Massachusetts will be required to submit a Criminal Offender Record Information (“CORI”) acknowledgement form. The Secretary of State published proposed changes to the Investment Adviser regulations in March. The … Read more »