Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure

Tag: Thomas O. Gorman

Don’t Lie to the Feds When Caught for Insider Trading

Doug Cornelius October 25, 2010 Insider Trading   3

The “classical theory” of insider trading targets “a corporate insider’s breach of duty to shareholders with whom the insider transacts[, and the] misappropriation theory outlaws trading on the basis of nonpublic information by a corporate ‘outsider’ in breach of a duty owed not to a trading party, but to the source of the information.” See … Read more »

What Do You Get For Cooperation with the SEC?

Doug Cornelius July 28, 2010July 27, 2010 SEC News   [+]

More likely to get sanctioned. Reduction of $30.3 million in penalties when you initiate your own investigation. Reduction of $609,000 in company penalties for each week earlier the statement is announced the public. Reduction of $112,000 in personal penalties for each week earlier the statement is announced the public. We in the compliance field have … Read more »

Fund Manager Fraud for Exceeding Leverage Limits

Doug Cornelius July 27, 2010July 27, 2010 Investment Advisers Act   2

It turns out that failing to adhere to your investment guidelines can not only get you sued by your investor, it can get you sent to jail. Mark D. Lay ran a hedge fund whose sole investor was the Ohio Bureau of Worker’s Compensation. The fund agreement had a non-binding 150% leverage guideline. Lay apparently … Read more »

Do Prosecutions Stop Insider Trading?

Doug Cornelius July 20, 2010July 21, 2010 Compliance Programs   [+]

We generally assume that the prosecution of crime acts as a deterrence to others who may think about committing the crime. One of the key factors in fraud is opportunity. If the wrongdoer thinks they can not get away with the violation, they are less likely to commit the violation. At least that is the … Read more »

Questions and Answers with Robert Khuzami

Doug Cornelius January 13, 2010July 21, 2010 SEC News   7

After the news conference announcing the Rearrangement of its Enforcement Program, the Securities and Exchange Commission offered a group of bloggers the chance to ask questions to Robert Khuzami, the Director of Enforcement. (It must have felt like Obi-Wan stepping into the cantina full of low-life scoundrels.) The blogging participants: Todd Sullivan of Value Plays … Read more »

Insider Trading Enforcement

Doug Cornelius October 20, 2009October 19, 2009 Insider Trading   [+]

Either the Securities and Exchange Commission has stepped up its enforcement of insider trading or it’s doing a better job of publicizing its enforcement. Earlier this week, the SEC announced its case against Raj Rajaratnam and his New York-based hedge fund advisory firm Galleon Management LP. On September 23, they charged Reza Saleh with insider … Read more »

The 2008 Year in Review from Securities Docket

Doug Cornelius January 6, 2009July 21, 2010 Corporate Governance   [+]

This panel joined Securities Docket’s Bruce Carton to look back at the most important and interesting developments in 2008, and offer their predictions for 2009. Walter Olson (Point of Law; Overlawyered),  Kevin LaCroix (The D&O Diary) Tom Gorman (SEC Actions) Francine McKenna (re: the Auditors) Kevin started off noting that the number of securities class … Read more »

Search for Stuff

Recent Stories

  • FCPA Comes Back From the Dead
  • The One with Uncertain Fees
  • Rising Backlash at the Killing of the Corporate Transparency Act
  • The Danger of Block Trading Accounts
  • SEC Report on Beneficial Ownership Concentration and Fund Outcomes for Hedge Funds
  • The MCAs Are Crankin’
  • Safeguard of Your IRA Was Not So Safe
  • The One Without an Anchor
  • Shuffling Silver at Silverback
  • SEC Has a Setback on Disclosure Case

Fight Cancer

Please support my Pan Mass Challenge to fight cancer.
Powered by WordPress & Undedicated theme by ReduxThemes.com.