These are some of the compliance-related stories that recently caught my attention.
A Compliance Plan or a Compliance Idea? by John Nocero in SCCE’s The Compliance & Ethics Blog
Much of what we do is dictated by our compliance plan. But we also need to be able to react based on arising risks or incidental findings. Often, being able to reprioritize is most important. I write a goal list of what I am going to get done each week, but some weeks are impossible to predict. You often need to make changes in real-time. Very rarely you can ever say you are totally locked in to a particular plan. Maybe it is better to characterize the compliance plan as a compliance idea – you are pointed in the right direction, but you are ready to make an adjustment if needed. [More…]
GP charged for failing to disclose portfolio company loans By: Katherine Bucaccio in Private Funds Management
The US Securities and Exchange Commission (SEC) has charged San Francisco-based private equity firm JH Partners for failing to disclose loans that the firm made to its portfolio companies, according to an SEC order filed at the end of last month.
The SEC claims that JH Partners and some of its principals provided approximately $62 million in direct loans to portfolio companies across three of its funds from 2006 to 2012. Through the loans, the firm acquired interests in the portfolio companies that were senior to the equity interests held by the funds, however, JH Partners did not disclose the loans or the potential conflict of interest to its LPs. [More…]
Unfair & Unbalanced Podcast with Tom Fox & Roy Snell – Episode #1
Taped at SCCE’s 2015 Compliance & Ethics Institute at the ARIA in Las Vegas. In this first episode, noted FCPA lawyer and blogger Tom Fox, and Society of Corporate Compliance & Ethics CEO, Roy Snell, discuss the importance of an independent compliance officer, misconceptions about compliance in general (hint: it’s not that hard), updating the Federal Sentencing Guidelines, the most important word in the Yates Memo, and some of the immediate effects of the Volkswagen scandal. [More…]
Brick in front of Belly Timber by Eli Christman
CC BY
