These are some of the compliance-related stories that I’ve been reading.
Mulvaney’s CFPB plan is dangerous by Rob Blackwell in American Banker
On Monday, Mulvaney called for four major reforms to CFPB: putting it on Congressional appropriations; creating a dedicated inspector general (currently the Federal Reserve’s inspector general oversees it); giving the president more oversight of the bureau; and, most importantly, subjecting all major new rules to Congressional approval. This fourth suggestion, a version of the so-called REINS Act that some conservative Republicans have been pushing for years, is by far the most dangerous and far-reaching. [More…]
Ethical Decision-Making in Business: Why Good People Do Bad Things by Laura Petrolino
This means it’s now more important than ever to be very clear about our ethical decision-making processes.
Where do we draw the line?
How do we work with our team and clients to make decisions?
[More…]
Directors and compliance programs: a look at the law by Jeff Kaplan in Conflict of Interest Blog
In an article to be published in the Temple Law Review – and summarized on the Harvard Law School Corporate Governance Forum – Professor Donald C. Langevoort of the Georgetown University Law Center takes a look at the role that Caremark has played over the last 20 years in encouraging directors to promote compliance at their respective companies. It is a thoughtful and informative piece that is strongly recommended for those who advise boards on C&E matters. Among other things, it can help such advisors avoid making the mistake that I nearly did, and instead focus on the legal expectations that matter most to boards. [More…]
SEC Discusses Online Trading Platforms — With a Word of Caution by Stephen J. Crimmins in The CLS Blue Sky Blog
On March 7, 2018, the Securities and Exchange Commission’s Enforcement Division and its Trading & Markets Division issued a joint “Statement on Potentially Unlawful Online Platforms for Trading Digital Assets.” The release appeared to be the strongest signal yet of a broadening of the SEC’s enforcement and regulatory interest beyond its focus over the last year on the need for certain coin offerings to be registered or to qualify for an exemption as private placements. [More…]
WORLD SERIES BANNERS AND RED FLAGS by Tom Fox in FCPA Compliance & Ethics
The 2017 World Series Champions, the Houston Astros, had their home opener on Monday evening. After 56 years and a few minutes of frustration (more on that later) the World Series (WS) banner was unveiled. As it is metal it could not be unfurled. It was a moment every Astros fan had literally waited their lifetime to see. Yet even with this triumphant moment the hometown heroes provided a few distinct lessons learned for the compliance practitioner, one around red flags. [More…]
Hey Doug! Thanks so much for including me in this great line up. So glad you found it useful.