These are some of the compliance-related stories that caught my attention while getting ready for Halloween!
The Results Are In – SCCE’s 2015 Salary Survey Report Is Now Available by Adam Turteltaub in SCCE’s Compliance & Ethics Blog
The Society of Corporate Compliance and Ethics (SCCE)® is pleased to be able to provide you with the 2015 Compliance and Ethics Officer Salary Survey report. As you will see, we have included data on compensation for both the chief compliance and ethics officer as well as for the compliance staff, giving a fuller picture of the compliance profession in one document. [More…]
California’s Secured Promissory Note Exemption by Keith Paul Bishop in California Corporate & Securities Law
The line between real property transactions and securities transactions is not always clear. California Corporations Code Section 25100(p) provides an exemption for a promissory note secured by a lien on real property provided it is neither: (a) one of a series of notes of equal priority secured by interests in the same real property; or (b) a note in which beneficial interests are sold to more than one person or entity. However, the fact that a secured note may be exempt under Section 25100(p) will only take you so far.[More…]
“Behavioral compliance”: the will and the way by Jeff Kaplan in Conflict of Interest Blog
“Behavioral ethics” information and ideas have, to date, been used far more to identify ethical challenges than to design approaches to address such challenges. In “Behavioral Ethics, Behavioral Compliance” (which can be downloaded for free here ) Professor Donald C. Langevoort of the Georgetown University Law Center takes up this latter task, and provides a number of practical suggestions for compliance-and-ethics (“C&E”) professionals to consider in applying this body of knowledge to their day-to-day work. [More…]
Are compliance officers crazy? by Richard L. Cassin in The FCPA Blog
So is it crazy to be a compliance officer?
Albert Einstein said insanity is doing the same thing over and over and expecting different results.
Expectations, then, are the key. With the verdict of history in mind, it’s crazy for a compliance officer to expect to bat a thousand against graft. Or to look for constant salutes from the C-suite. Or to think of all prosecutors, regulators, judges, and politicians as natural allies.[More…]
Whom Should You Suspend During an Internal Investigation? by Thomas Fox in FCPA Compliance & Ethics
Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to reverberate, it continues to bring up some very knotty questions, which have bedeviled the Chief Compliance Officer (CCO) or compliance practitioner in many areas. Today there is an example around internal investigations.[More…]
What qualities should a CCO have; here are nine. by Joshua Horn in Securities Compliance Sentinel
Andrew Donohue, SEC Chief of Staff, recently commented on what a person needs in order to be a competent CCO; he identified nine things. The overarching theme from this list is experience. According to Donahue, in no particular order, a CCO must:
- Have a “first hand knowledge” of the regulatory environment.
- Have a detailed understanding of the firm, its operations and structure.
- Be able to readily identify conflicts of interest, report and resolve them.
- Have an understanding of the firm’s business model, including knowledge of firm available products and their profitability.
[More…]