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Doug Cornelius on compliance for private equity real estate

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Tag: MSRB Rule G-37

SEC Brings a Pay-to-Play Action

Doug Cornelius October 1, 2012October 1, 2012 Fundraising   [+]

The Securities and Exchange Commission filed a “pay-to-play” case against Goldman Sachs and one of its former investment bankers, Neil M.M. Morrison. The SEC alleges that Goldman and Morrison made undisclosed campaign contributions to then-Massachusetts state treasurer Timothy P. Cahill while he was a candidate for governor. The case was brought under the Municipal Securities … Read more »

Placement Agents and the MSRB

Doug Cornelius December 13, 2010March 2, 2012 Compliance Programs   [+]

In addition to laying out the changes to Form ADV, in Release No. IA-3110 the SEC also took a slightly different course on regulating placement agents. Rule 206(4)-5, released in July 2010, required placement agents to either be registered with the SEC as an investment adviser and subject to the limitation on campaign contributions, or … Read more »

SEC Warns Firms on Muni Pay-to-Play Rules

Doug Cornelius March 22, 2010March 19, 2010 Compliance Programs   1

While sources are wallowing in the exposure of a political figure in a “pay to play” scandal, I thought there might be some lessons for other investment managers as states and perhaps the SEC roll out limitations on political contributions. The original story seemed mildly interesting.  The SEC warned firms that municipal securities rules prohibiting … Read more »

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