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Compliance Building

Doug Cornelius on compliance for private equity real estate

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Crowdsourcing the Purchase of a Beer Company

Doug Cornelius June 9, 2011September 19, 2017 Fundraising, Publish to KM Space   [+]

Some beer lovers who were fans of Pabst Blue Ribbon heard that its parent company, the Pabst Brewing Co., was up for sale. The previous owner had died, leaving it to a charitable trust. Charities couldn’t hold on to the asset so they had to sell it. The beer lovers were a few hundred million … Read more »

Does it Matter Where the Signature Is?

Doug Cornelius June 8, 2011 Compliance Programs   4

Just about every compliance certification has the employee sign at the bottom. We have been signing letters and contracts at the end for millenia. But maybe there is a way to increase ethical performance by moving that signature to the top. Lisa L. Shu, Nina Mazar, Francesca Gino, Dan Ariely, and Max H. Bazerman recently … Read more »

Compliance Lessons from Weinergate

Doug Cornelius June 7, 2011June 7, 2011 Publish to KM Space, Social Networking and Web 2.0   [+]

In a tearful statement to the media, Rep. Anthony Weiner admitted he posted a lewd picture of his anatomy to Twitter. Not only that, he says he’s engaged in “inappropriate” online communications with at least six other women. It was just a few days ago that I revisited the Fabulous Fab Rule: Don’t write emails … Read more »

Lessons from Wunderlich

Doug Cornelius June 6, 2011June 3, 2011 Compliance Programs   1

I don’t take pleasure from others’ failings, but I do try to learn lessons. The recent settlement between Wunderlich Securities and the Securities and Exchange Commission is full of lessons to be learned. overcharged advisory clients for commissions and other transactional fees in violation of Section 206(2) of the Advisers Act failed to satisfy the … Read more »

Compliance Bits and Pieces for June 3

Doug Cornelius June 3, 2011June 3, 2011 Compliance Bricks and Mortar   [+]

Here are some recent compliance-related stories that caught my attention: Launching Into Unethical Behavior: Lessons from the Challenger Disaster by Ann E. Tenbrunsel and Max H. Bazerman in Freakonomics On the night before the Challenger was set to launch, a group of NASA engineers and managers met with the shuttle contracting firm Morton Thiokol to … Read more »

Paying a Bribe? There’s an App for that

Doug Cornelius June 2, 2011March 17, 2013 Bribery and Corruption   1

Can you crowdsource the fight against corruption? An international team coming from Estonia, Lithuania, Finland and Iran thinks you might. They created a smartphone app that allows people to anonymously report incidences of bribery and later see the data visualized on an interactive map. Bribespot is an app that allows you to see how much … Read more »

Revisiting the Fabulous Fab

Doug Cornelius June 1, 2011 Records Management   1

Last summer, Fabrice Tourre didn’t turn around fast enough to see the bus coming at him. Goldman Sachs had given him a big push and put him in the front and center of their big bet on a crash in the residential mortgage securities market. Tourre ended up as the Fabulous Fab after giving himself … Read more »

Felons and Fund Managers

Doug Cornelius May 31, 2011September 29, 2013 SEC News   [+]

Most private funds rely on a Rule 506 exemption under Regulation D to sell their limited partnership interests to investors. A new SEC rule amending Rule 506 should catch the eye of private fund compliance officers. The concept it fairly straight-forward: felons should not be allowed to take advantage of the private offering exemptions. Dodd-Frank … Read more »

Compliance Bits and Pieces for May 27

Doug Cornelius May 27, 2011 Publish to KM Space   [+]

Here are some compliance-related stories that recently caught my eye: Gold is Not an Investment by Carl Richards in the NY TImes.com’s Bucks Gold is not an investment. It’s a speculation. Investments are made by evaluating underlying value. Speculative bets are made by looking at the price of something and simply hoping the price goes … Read more »

The New SEC Whistleblower Rule

Doug Cornelius May 26, 2011March 17, 2013 Whistleblower   1

In a blow to the efforts of internal compliance, the SEC will let corporate whistle-blowers collect a percentage of penalties when they report financial wrongdoing, even when they bypass companies’ internal complaint systems. “For an agency with limited resources like the SEC, it is critical to be able to leverage the resources of people who … Read more »

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