Doug Cornelius on compliance for private equity real estate
If your Thanksgiving was anything like mine, you have leftover food. It’s a poor allocation of resources, but Thanksgiving has turned into a weekend of excess. Excess food, excess shopping, excess football, excess dessert, excess waistline. Perhaps your compliance program is also filled with leftovers. Very few compliance officers would say that they have more … Read more »
There has been considerable discussion in the compliance community around the Securities and Exchange Commission bringing charges against compliance officers. There are three areas that the SEC feels it is justified in bringing charges: (1) when the compliance officer is involved in the wrongdoing; (2) when the compliance officer impedes the examination or investigation; and … Read more »
That means an extra long weekend for me. In Boston, the big traffic rush was on Tuesday night to avoid the traffic on Wednesday. I think most people have a half day on Wednesday or the day off. I hope you get to enjoy a long weekend before the push for year-end. I’m going for … Read more »
If you are looking for something to read during the long Thanksgiving Weekend or a great holiday present, pick up a copy of the newly released The US Private Equity Fund Compliance Guide, Volume III. PEI Media just released this follow up that updates the original 2012 edition with the ongoing review and actions of … Read more »
Last week at the Coping With Regulatory Failure conference, representatives from Securities and Exchange Commission repeated the SEC’s line that the SEC is not after compliance officers. But yet another case of CCO liability came out and this one kicks the CCO out of the industry and levels a $60,000 fine. The SEC panelists repeated … Read more »
These are some of the compliance-related stories that recently caught my attention. Attributes of a Great Ethics and Compliance Leader by Jean-Marc Levy in Corporate Compliance Insights The three most important qualities of a CECO are courage, a deep understanding of his/her business and emotional intelligence. These qualities go beyond the traditional role of an … Read more »
Eighteen months ago, Andrew Bowden gave his Sunshine speech on the SEC’s disapproval of private equity fee compliance. Now, enforcement cases are being finalized on private equity fees. The SEC is just now finishing a focus on real estate funds. Should we be looking for real estate fund enforcement cases on the horizon? While listening … Read more »
I’m attending a conference sponsored by IA Watch: Coping with Regulatory Change. These are my brief notes. Luis Mejia, Partner, Perkins Coie, Washington, D.C.; Walter Ricciardi, Partner, Paul, Weiss, Rifkind, Wharton & Garrison, New York; and Bruce Karpati, Global CCO/Director, KKR, New York provided their view, now that they are on the other side. You … Read more »
I’m attending a conference sponsored by IA Watch: Coping with Regulatory Change. These are my brief notes. Anthony Kelly, Assistant Director, SEC’s Asset Management Unit, shared some of the activities of this part of the Securities and Exchange Commission. For fees, the Unit is looking mis-allocation of private equity fees and expenses and whether the … Read more »
I’m attending a conference sponsored by IA Watch: Coping with Regulatory Change. These are my brief notes. Marc Wyatt, Director, SEC’s Office of Compliance Inspections and Examinations, gave his perspective on the priorities that lie ahead for OCIE. Marc Wyatt Named Director of the Office of Compliance Inspections and Examinations last week. He emphasized that … Read more »