Investors look for transparency in fees. The Institutional Limited Partners Association published a Fee Reporting Template Last Week to encourage uniformity in the fee disclosures being made to private fund investors. The aim of this proposed template is to encourage increased uniformity in the fee disclosures the fund managers provide to limited partners in private … Read more »
The Good, Bad and the Ugly of Lending
In browsing through the Wall Street Journal I ran into three stories side by side: China Calls Lending Platform Ezubo a $7.6 Billion Ponzi Scheme J.P. Morgan Acquires Nearly $1 Billion Worth of Lending Club Loans Remember ‘Liar Loans’? Wall Street Pushes a Twist on the Crisis-Era Mortgage Each is a different side of specialty … Read more »

It’s Hard to Tell What the Next Form of Cheating Will Look Like
One of the problems with compliance is that the fraudsters seem to be one step ahead of the regulators. The regulators try to push out rules to prevent bad behavior. Regulators look at their charges to find cheating. But the cheaters are often one step ahead. We saw this in professional cycling over the weekend. … Read more »

Compliance Bricks and Mortar for January 29
These are some of the compliance-related stories that recently caught my attention. U.S. Banks Cut Off Mexican Clients, as Regulatory Pressure Increases by Rachel Louise Ensign, Emily Glazer and Amy Guthrie in the Wall Street Journal At issue are correspondent-banking relationships that allow Mexican banks to facilitate cross-border transactions and meet their clients’ needs … Read more »
A Small Step Forward in Real Estate Anti-Money Laundering
Real estate in the United States has been rumored to be an interesting place for hiding money. In particular, the US Treasury is concerned about illegal money getting filtered through US real estate. Until now, FinCEN has mostly relied on anti-money laundering protections on real estate transactions involving lending. FinCEN is now looking at vulnerabilities … Read more »
The SEC’s Insider Trading Case Falls Further Apart
Five years ago, the SEC came crashing into the offices of Level Global Investors accusing it of engaging in illegal insider trading. The firm agreed to pay $21.5 million in settlement money to resolve that insider trading investigation. Now it wants its money money back. When it comes to insider trading, it’s not the firm … Read more »
The SEC Tries to Shut Down Another Failed Real Estate Investment Scheme
One of the challenges faced by the Securities and Exchange Commission when encountering a real estate scam is finding jurisdiction. The SEC is limited to securities and a real estate investment is not a security. But a real estate investments may involve securities or be a securities-like investment. That is the case the SEC is … Read more »

Weekend Reading: Lights Out
Should we worry about an attack on the Untied States’ electrical infrastructure? Ted Koppel says “very much so” in his book: Lights Out. You probably better know Mr. Koppel as the longtime anchorman on ABC News and Nightline. In Lights Out he puts on his old school journalist hat and puts together an in depth … Read more »
Compliance Bricks and Mortar for January 22
These are some of the compliance related stories that recently caught my attention. Corporate Disclosure, Social Policy, and Dirty Pool by Matt Kelly in Radical Compliance [L]et’s use the Conflict Minerals Rule as the flagship example of a much broader bad idea in Dodd-Frank—using federal securities law to force social policy on corporations. Because as … Read more »

Could Whistleblowing Be The New Short-Selling?
The Securities and Exchange Commission made an unusual announcement this week, announcing a whistleblower award to a company outsider. Could this been a new way to profit from companies engaged in fraud? Is this a new alternative to short selling? Earlier this week, the SEC announced a $700,000 award to a company outsider who conducted … Read more »