Doug Cornelius on compliance for private equity real estate
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 »
A friend in the private fund compliance community just came up with another “gotcha” under the Custody Rule. His client used an auditor that was registered with PCAOB, but had not yet been inspected. He thought it was enough to be registered, while waiting for an inspection. An SEC examiner argued that the auditor needed … Read more »
There are few among us who think the high cost of getting elected and fundraising that it requires is good for American politics. The SEC took a moral high ground and passed Rule 206(4)-5. That rule effectively prohibits investment managers from making political contributions to politicians who control pension money, other than small token amounts. … Read more »
The world got a little less interesting now that this big, bold, brash guy has left it. I have not posted in Compliance Building while I’ve been trying to deal with this loss. My best friend, Jeff Levine, was diagnosed with cancer just before Thanksgiving. He lost his battle against the disease last week. Jeff … Read more »
In browsing through enforcement actions I look for lessons learned. In some cases it’s compliance doing its job and stopping a fraud before it gets too big. The case against Owen Li caught my eye. His trades were not working so he made a last ditch effort to make it all back. Given that this … Read more »
I hope you were able to enjoy the long weekend. Perhaps an extra long weekend if you found December 31 to be an optional work day. Today is obviously not the first day of the new year, but it is the first day of work in the new year. With the new year, come the … Read more »
Happy New Year! May 2016 be better for you than 2015. These are some of the compliance related stories that caught my eye before the end of 2015. Compliance Fiction by Roy Snell in SCCE’s Compliance & Ethics Blog Let me tell you a completely fabricated compliance story. [More…] The Father of Texas and Leadership … Read more »
Whether 2015 was a great year or a terrible year for you, I hope that 2016 will be a better year. I hope that some of the stories I published this past year were useful. Be compliant in 2016 Read more »
With my 2015 almost gone, I was thinking about what to expect in 2016 in the private fund and real estate fund compliance area. My crystal ball is not very reliable. If it was fully operational, I would have bought Apple stock in 2002 before the iPod came out. Real Estate Fund Enforcement Actions There … Read more »
Cybersecurity is a real threat and needs to be taken seriously. But is it a Board of Directors level issue for all public companies? I don’t think so. But apparently Senators Jack Reed and Susan Collins think that is. That would mean another headache for public companies. Of course there may be some companies that … Read more »