March 17th may mean Saint Patrick’s Day to most of you. Here in Boston it’s Evacuation Day. The holiday commemorates the evacuation of British forces from the city of Boston following the Siege of Boston, early in the American Revolutionary War. (It’s just a coincidence that it coincides with Saint Patrick’s Day.) George Washington fortified … Read more »
Dodd’s Solo View on Private Investment Funds
Senator Dodd did not forget about private investment funds. Tucked into page 366 of his 1366 page Restoring American Financial Stability Act of 2010 is the Private Fund Investment Advisers Registration Act. This is largely the same language in the Private Fund Investment Advisers Registration Act of 2009 contained in Dodd’s draft Restoring American Financial … Read more »
Dodd Goes Solo
After months of negotiation, Senator Dodd gave up on his negotiations with Republicans and decided to introduce a financial industry reform bill all by himself. To promote the financial stability of the United States by improving accountability and transparency in the financial system, to end ‘‘too big to fail’’, to protect the American taxpayer by … Read more »
Toyota, Ethics and Compliance
With Toyota’s problems all over the news, I started to think about whether compliance and ethics professionals could learn anything from these problems. To begin, I don’t think there is a systemic problem with their vehicles or with the company. I think the sudden acceleration problem is bunk. Yes, I own a Toyota, but my … Read more »
MoFo2Go
Do I care if my law firm has an iPhone App? As client, I care about my law firms delivering useful information to me. Kevin O’Keefe says your law firm should forget about building an iPhone App. Morrison & Foerster didn’t heed his advice and created MoFo2Go, an iPhone app. iPhone App versus Mobile View … Read more »
Compliance Bits and Pieces for March 12
Here are some compliance stories from the past week that I found interesting: Shadowing a Swindler by Richard Tofel His review of the Harry Markopolos book: No One Would Listen [N]early all the whistleblowers she had met shared two qualities. First, they were onto something—that is, there was at least some truth to what they … Read more »
Upcoming Appearances and Conferences
For those of you stalking me or trying to find out when my house is empty, here are some places I will be this spring: Mark Fryenburg asked back to his speak to his class: CS 299 Web 2.0: Technology, Strategy, Community. I’m going to tackle personal knowledge management. After all, that is the reason … Read more »
Consumer Complaints and Fraud
I occasionally like to look at consumer fraud complaints to see if I can learn any lessons for corporate compliance.On the consumer side there is tremendous volume of complaints and many parties trying to help. It caught my eye when four different organizations got together to identify the top consumer complaints for 2009. Here are … Read more »
The Problem with Selective Disclosure
If you want to see a classic case of the problems with selective disclosure take a look at the recent SEC case against Presstek, Inc. and its former CFO. Presstek was having a bad quarter in 2006. The CFO knew that the company would be reporting bad financial performance for the quarter. The CFO told … Read more »
New Codes of Conduct for Real Estate Companies
It’s always useful to look at what your competition is doing. The same is true in drafting your code of conduct (or code of ethics or whatever name you chose). It is useful to look at you what your competitors’ codes of conduct look like. Since Sarbanes-Oxley requires a public company to have a code … Read more »