Doug Cornelius on compliance for private equity real estate
With the pending release of Episode VIII – The Last Jedi, I’m joining Tom Fox in tying compliance and the Star Wars franchise together. Starting at the beginning with Star Wars, or what is now Episode IV – A New Hope, the climax is the destruction of the Death Star. One of the complaints about the … Read more »
These are some of the compliance-related stories that recently caught my attention. ICO Enforcement Actions Threatened, ICO Lawsuits Proliferate By Kevin LaCroix According to the latest update on the Coinschedule website (here), there have been a total of 228 initial coin offerings so far this year through mid-October, raising a total of over $3.6 billion. At least … Read more »
Private funds are often dealing hard-to-value assets. Real estate funds are overwhelmingly dealing with hard-to-value assets. For purposes of GAAP reporting those will be the Level 2 and Level 3 assets. For these assets, valuations can be manipulated if you have a wiling participant in the process. For thinly-traded securities, like some bonds, private funds … Read more »
On Tuesday, the Russian Olympic Committee was suspended from participating in the Olympic Winter Games at PyeongChang in February 2018. The action was in response to “the systemic manipulation of the anti-doping rules and system in Russia, through the Disappearing Positive Methodology and during the Olympic Winter Games Sochi 2014″. These penalties for doping are without precedent in … Read more »
With Bitcoin hitting stratospheric pricing levels, there are scams aplenty trying to cash in on tulip-mania around Bitcoin. This chart from the Wall Street Journal says it all. Of those trying to cash in, I’m sure some actually have legitimate business purposes and are trying to find new ways to operate financial systems. But many … Read more »
In a stunning turn, the Securities and Exchange Commission altered its treatment of the SEC’s administrative law judges. There have been several challenges to the constitutionality of these in-house judges. It appears that the Trump administration’s Department of Justice changed position and perhaps undercut the position of the SEC. That caused the SEC to change it’s … Read more »
The case for self-reporting failures has always been a nebulous promise from the government that the enforcement will be more lenient than if not self-reported. There has been limited proof that this has been true. That may be largely because we don’t hear about the self-reported problems because there is little to no government action … Read more »
With BitCoin breaking through the $10,000 barrier and growing interest in the uses of the underlying blockchain technology, everyone is looking to cash in using virtual currency. As with an IPO, the goal of investors in an Initial Coin Offering is get in early and cheap before the market takes the price up. The Securities … Read more »
The Consumer Financial Protection Bureau has been a political hotspot since it was first proposed in the wake of the 2008 financial crisis. The Republican leadership miscalculated in blocking Elizabeth Warren from becoming the first CFPB Director, which allowed her to turn to election as Senator and becoming a much larger political figure. Her replacement … Read more »
Instead of shopping (or working), I’m off on a bike ride. If you are looking for something compliance-related to read, here are few stories that recently caught my attention. Stock Trades of SEC Employees by Shivaram Rajgopal (Columbia Business School) and Roger M. White (Arizona State University) In March 2009, H. David Kotz, then Inspector … Read more »