Over the years, the Financial Crimes Enforcement Network (FinCEN) has required banks, brokers, and other financial entities to officially report suspicious activities of its customers. Investment advisers and private fund managers have managed to sty outside the requirements. In large part, that’s because a fund’s custodial accounts are already subject to the self-policing. since the … Read more »
Updated List of Other Blogs I Read
In starting off the new year I thought I would update my blogroll, that list of other sites that I read on a regular basis. There is a link to it in the top menu bar of the website. Rather than make you have to chase back to the website, I have also included the … Read more »
Compliance Bricks and Mortar for January 4
These are some of the compliance related stories that caught my attention during this first week of 2013 and last week of 2012. Khuzami Posts Blog Comment Defending SEC’s Record, Policies by Bruce Carton in Compliance Week In a December 27 post, Johnson wrote that as Robert Khuzami will reportedly soon step down as Director … Read more »
What I Read in 2012
The Goal One of my recurring annual goals is to finish reading at least 26 books for the year. In 2012, I managed to finish 36. Although, 6 of those were lighter reads. So maybe I should discount those and bring it down to 30. In any event, I exceeded my goal. The full list … Read more »
Is a General Partnership Interest a Security?
When the SEC announced an asset freeze against Western Financial Planning Corporation and its principal Louis Schooler, I was a bit troubled by the structure of the investments in question. The firm had structured the real estate investment vehicles as general partnerships. The presumption is that a general partnership interest is not a security. So … Read more »
Happy New Year’s Eve
Center of town. Woodstock, Vermont. “Snowy night” (1940) by Marion Post Wolcott Published by the Library of Congress Read more »
Compliance Bricks and Mortar for the End of 2012
It’s been a slow week in compliance. The highways and trains have been near empty during my commute. It seems there are more seagulls than people in the Financial District. But a few compliance-related stories caught my attention. Why a Popular Subsidy for Banks Died in the Senate by John Carney in CNBC’s NetNet The … Read more »
The Physics of Wall Street and its Failures
Warren Buffett famously warned, “beware of geeks bearing formulas.” After the Great Panic of 2008, many pundits placed the blame on derivatives and other “complex financial instruments.” That would lead one to believe that the blame lies with the physicists and mathematicians who dreamed them up. James Owen Weatherall decided to look behind that blame … Read more »
Happy Holidays
May you receive all the compliance gifts you’ve dreamed of. Cats Decorating Christmas Tree by Louis Wain in the Detroit Publishing Company Collection at the Library of Congress Read more »
Compliance Bricks and Mortar – Mayan Apocalypse Edition
If you’re reading this, then the Mayan Apocalypse didn’t happen. (At least not yet.) That means back to work and a look at some of the compliance stories that caught my attention recently. Dispatches From the Front Lines of the Ethics & Culture Wars by Matt Kelly in Compliance Week Does your organization know what … Read more »