Friday marked the effective date of the SEC’s Whistlelower Rule. Lucky whistleblowers can now cash in with bounties of up to 30% of the government’s recovery when cases involve in excess of $1 million. The question I have is whether there was spike in tips submitted over the weekend? The SEC is trying to make … Read more »
Compliance Bits and Pieces for August 12
These are some compliance-related stories that recently caught my eye: United Breaks Guitars: Lesson Learned for Companies and Whistleblowers by Tom Fox The authors break their analysis down into two components, which I believe relate to the compliance context. The first is to understand what would drive an employee to go outside the internal reporting process? … Read more »
Remind People to Do the Right Thing
Dan Ariely continues to find small, easy ways to change behavior. This time it was his students running the experiment instead of him. Two students sent an email to everyone in the class that included a link to a website that was supposed to contain the answers to a past year’s final exam. In half … Read more »
Laundering the Proceeds of Corruption
The FCPA and the Bribery Act focus mostly on the giver of the bribe. On the other hand, the recipients of the bribes need to deal with the cash to also avoid being caught. Like all criminals, they either shove cash into their mattresses or find a way to launder the money to get it … Read more »
Compliance and Liar’s Poker
Michael Lewis has written some great stuff on our most recent financial crisis: The Big Short, Iceland’s Meltdown, Greece and Corruption, and Popping the Irish Bubble. This was not his first rodeo. Lewis had a brief career in finance working as a London-based bond salesman for Solomon Brothers during the mid eighties. His finance career … Read more »
Pillow Talk at Playboy Leads to Insider Trading
The headline was too hard to ignore. I suppose there must be some compliance lessons to be learned. But first, the facts: William A. Marovitz, who is married to former Playboy Enterprises Inc. Chief Executive Officer Christie Hefner, made $100,952 on the trades, according to an SEC complaint. The SEC alleges that on five occasions … Read more »
Compliance Bits and Pieces for August 5
Is it August already? The summer is flying by (as usual). There are still some interesting compliance-related stories floating by on the interwebz. Don’t know if you’re carrying on business in the UK, or not? What do you do? in The Bribery Act .com The key to its long arm jurisdiction rests in its application … Read more »
Report on Mutual Fund Advertising
Section 918 of Dodd-Frank Act required a study on mutual fund advertising. The Government Accountability Office delivered that report before the 18 month deadline to the designated Congressional committees. The Report’s objectives were “to examine (1) what is known about the impact of mutual fund advertisements on investors, (2) the extent to which performance information … Read more »
Risk Retention and Funding Private Equity Deals
There is no doubt that securitization helped fuel the residential housing bubble that lead to the Great Panic of 2008. Lenders found ready buyers for their loan portfolios, could sell them, then lend the money out again to create new loan portfolios to resell. One of the issues is that the lenders became purely loan … Read more »
What is the SEC Looking For With Private Fund Managers
IA Watch published a few recent document request letters in connection with SEC examinations of investment advisers. One is a document request letter sent to a private fund manager (sub. required). These are some of the items requested that caught my attention: Organizational chart showing ownership percentages investment strategy Amount of adviser’s equity interest Amount … Read more »