One part of compliance is investigation. Find the facts. Don’t rely on opinion or self-interest statements. With all the hullabaloo about the Ground Zero Mosque I thought I would gather some factual information. First off. It’s not at Ground Zero. Just How Far Is the “Ground Zero Mosque” From Ground Zero? by Matt Sledge in … Read more »
Year: 2010
SEC versus New Jersey
Fuggedaboutit! New Jersey became the first state ever charged by the SEC for violations of the federal securities laws. They gave up without a fight and agreed to settle the case, without admitting or denying the SEC’s findings. This matter involves the sale of over $26 billion in municipal bonds from August 2001 through April … Read more »
Criminal Provisions under Dodd-Frank
When thinking designing compliance programs, I pay extra attention to the issues that can result in jail time. It’s one thing to pay a fine, it’s a much bigger problem when you take someone’s freedom away. The Dodd-Frank Wall Street Reform & Consumer Protection Act has added several new federal criminal offenses. The National Association … Read more »
EWWW! The Connections Between Disgust and Morality
What if our moral judgments are simply that a situation makes us feel like throwing up? Drake Bennett explores some of the new research and thinking in how our moral ideas may have evolved from our more visceral feelings of disgust in Ewwwwwwwww! The surprising moral force of disgust. The moral emotions model has another … Read more »
The Ascent of Money: A Financial History of the World
Niall Ferguson had the unfortunate luck of writing The Ascent of Money just before the unveiling of the 2008’s Great Panic. At the time he finished writing the book in May 2008, only $318 billion of write-downs had been acknowledged. I was interested in the book because of its focus on the development of our … Read more »
Compliance Bits and Pieces: Mark Hurd Special
Last Friday, the big news in compliance was the sudden resignation of Mark Hurd as the CEO and Chairman of the Board of Hewlett-Packard. I decided to put together a compilation of other stories I found interesting. HP and me: Coincidence or not? by Michelle Leder in Footnoted Of course, footnoted had done its own … Read more »
Changes to the Qualified Client Standard
In addition to the changing standard for an accredited investor, the standard for a “qualified client” under the Investment Advisers Act is also changing. Section 418 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires the SEC to increase the standard. SEC. 418. QUALIFIED CLIENT STANDARD. Section 205(e) of the Investment Advisers Act … Read more »
Be the Mayor, not the Sheriff
Are you getting in the way or helping to move your organization forward? Inevitably, compliance professional will need to step in and stop an activity or start a discipline process for someone who broke the rules. That does not have to be the primary focus of the your job, or the compliance profession. Frank Sheeder, … Read more »
How Does Your Hotline Compare?
Does your hotline ring off the hook with complaints? Is it silent? Are the complaints mostly that the employee thinks his boss is a jerk? The Network and BDO Consulting published their 2010 Corporate Governance and Compliance Hotline Benchmarking Report. The 2010 report provides an analysis of compilation of more than 500,000 reports from over … Read more »
Mixed Messages from H-P
On Friday, Hewlett-Packard fired its CEO because he violated the company’s code of conduct. Mark Hurd had submitted inaccurate expense reports. That sounds like a good message from the Board. Anyone can be fired for violating the code. However, Mr. Hurd was given a severance package that may be worth more than $35 million, including … Read more »