Doug Cornelius on compliance for private equity real estate
Compliance Building is a resource I publish for me, and share with you, to help the compliance profession. It’s free. I’m not looking for any of your compliance budget. But I am hoping you will consider allocating a piece of your charitable donation budget to one of the charities I support: the Pan Mass Challenge. … Read more »
Alain Lille, CEO of Petronian Industries is not happy with the new government. He wants to protect his investment in the country of Petronia. His oil firm deployed a great deal of capital looking for oil in Petronia and had a contract with the government for production. A roadblock appeared in last year’s election. The … Read more »
Back in 2015, the Securities and Exchange Commission made it clear that providing jobs to family members of foreign government officials could be a violation of the Foreign Corrupt Practices Act. That SEC investigation found that BNY Mellon did not evaluate or hire the family members in accordance with its hiring standards and require a … Read more »
United Development Funding and its investment platforms have been under attack for a few years. It looks it has finally come to grips with its mistakes. UDF is closing out investigations into its funding of real estate investments from multiple investment platforms. The attacks started in 2015 when Kyle Bass, who runs Dallas-based hedge fund Hayman … Read more »
Study 2,690 cases of occupational fraud over 18 months and you may see some trends. The Association of Certified Fraud Examiners conducted a survey of its 41,000+ certified fraud examiners to collect data on the single biggest fraud case they investigated from January 2016 to October 2017. The study identified six behavioral red flags that … Read more »
Seven years ago the Securities and Exchange Commission opened its Office of the Whistleblower under the authorization of the Dodd-Frank Act. Since then the SEC has received over 22,000 whistleblower tips, obtained over $1.4 billion in financial remedies related to those tips, and ordered over $266 million in whistleblower awards to 55 individuals. Now, the SEC wants … Read more »
Government failed Flint, Michigan. In April 2014, Flint changed its water source from treated Detroit system to the Flint River. Officials failed to apply corrosion inhibitors to the water. As a result, there was a serious public health danger. The Flint River water caused lead from aging pipes to leach into the water supply. The … Read more »
The Securities and Exchange Commission and the DOJ filed another case against an Equifax employee who figured out that the breach remediation plan was actually for Equifax and not a client. Sudhakar Reddy Bonthu, like Jun Ying in the earlier case, Bonthu was working on Project Sparta which was identified as a fast-breaking opportunity for … Read more »
One of the 2018 exam priorities for the Securities and Exchange Commission is “matters of importance to retail investors.” The SEC has found many problems with advisers selling their clients higher cost share classes of mutual funds that paid the adviser a fee. It’s not that a registered investment adviser can’t take that 12b-1 fee. … Read more »
After last week’s Supreme Court decision in Lucia v. Securities and Exchange Commission, it’s clear that administrative law judges of the US Securities and Exchange Commission are not mere federal employees but qualify as “Officers of the United States” under the Appointments Clause of the US Constitution. That means they need be appointed by the … Read more »