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Compliance Building

Doug Cornelius on compliance for private equity real estate

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Tag: Wyoming

The Wild West of Wyoming

Doug Cornelius July 7, 2016 Investment Advisers Act   [+]

I run across compliance stories that make me scratch my head when I find something odd.  I just came across another that made me remember one of the quirks of registration with the Securities and Exchange Commission as an investment adviser. The SEC was after Timothy Sexton and his advisory firm, Bantry Bay Capital. Examiners showed … Read more »

Dislocated in Wyoming Again

Doug Cornelius February 24, 2015 Investment Advisers Act   [+]

At the fall NRS Conference, the presenter and the audience were both surprised to reveal that false addresses was a new enforcement initiative for the Securities and Exchange Commission when it came to registered investment advisers and fund managers. Two weeks ago, the SEC came out with three enforcement actions against advisers that had falsely … Read more »

The Lure of Wyoming

Doug Cornelius February 11, 2015February 11, 2015 Compliance Programs   [+]

There is a long history of splitting financial regulatory oversight between state regulators and federal regulators. For investment advisers the split is based on Assets Under Management and Dodd-Frank raised the AUM level from $25 million to $100 million. Above that level you register with the SEC and below that level you register with the … Read more »

What do Wyoming, New York, and Minnesota Have in Common?

Doug Cornelius June 28, 2011June 24, 2011 Investment Advisers Act   [+]

They don’t examine investment advisers. Wyoming has long been on this list because it does not have a law regulating investment advisers. In Item 2 of Form ADV there was a box to check if your principal office and place of business was Wyoming. That kept you in SEC registration. The importance of whether a … Read more »

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