Doug Cornelius on compliance for private equity real estate
The big news in compliance this week was the release of the Resource Guide to the U.S. Foreign Corrupt Practices Act (.pdf). But I have only had a chance to glance at it briefly. I’m underwhelmed, even after having low expectations. Since I have not read much, I’m posting the views of many others: Guidance … Read more »
The Securities and Exchange Commission and the Department of Justice jointly released A Resource Guide to the U.S. Foreign Corrupt Practices Act (.pdf). The 120-page guide provides a detailed analysis of the U.S. Foreign Corrupt Practices Act and closely examines the SEC and DOJ approach to FCPA enforcement. The guide addresses a wide variety of … Read more »
These are some of the compliance related stories that recently caught my attention. Fighting corruption with bumper stickers and public toilets: ambient accountability by Dieter Zinnbauer in Space for Transparency Take for inspiration this passenger bill of rights, displayed literally right in your face at the backrest of the driver’s seat in New York taxis. … Read more »
The last time Washington saw Elizabeth Warren, she was thrown out of town for her strong advocacy of the Consumer Financial Protection Bureau. The Dodd–Frank Wall Street Reform and Consumer Protection Act established the CFPB. Warren is credited with creating the CFPB, tirelesslessy lobbying for its inclusion in Dodd-Frank, and worked on implementation of the … Read more »
I’m not going to say that your vote counts. For the presidential election, your vote counts more if you live in Florida or Ohio. Your vote in a solidly red or blue state like Massachusetts or Texas counts less. However, there are likely plenty of other competitive races on your ballot, besides the presidential election. … Read more »
The Securities Division of the Massachusetts’ Secretary of State’s office filed an administrative complaint against CCR Wealth Management. The complaint seeks to deny CCR Wealth Management registration as an investment adviser. The secretary of state’s office said inspectors became suspicious when they noticed that CCR had reported static denominations over a period of time, even … Read more »
These are some of the compliance related stories that recently caught my attention. 21-Month Sentence Just One of the Consequences of Former Deloitte Partner’s Insider Trading by Bruce Carton in Compliance Week A big part of the SEC and DOJ’s enforcement of the insider trading laws is to bring cases that will deter others from … Read more »
Disaster recovery is an important, though not explicitly mandatory, component of compliance program. The Securities and Exchange Commission alludes to this in the release for the compliance rule. It’s also a key part of personal plan. I’m learning that first hand. My family is spending its third day without power. Fun and exciting at first, … Read more »
The latest Opinion Procedure Release from the Department of Justice comes from a group of non-profit adoption agencies. Based on the stories I’ve heard from friends who have adopted from overseas, I’m not surprised that adoption agencies are concerned about the Foreign Corrupt Practices Act. Opinion Release No. 12-02 is focused on an event hosted … Read more »
These are some compliance related stories that recently caught my attention. Enforcement Actions Against Advisors Nearly Doubled: NASAA by Melanie Waddell in AdvisorOne Enforcement actions taken against investment advisory firms by state securities regulators nearly doubled to 399 in 2011—accounting for 15% of all enforcement actions handled by state securities regulators, according to the North … Read more »