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Compliance Bricks and Mortar for November 15

Posted on November 15, 2019November 12, 2019 by Doug Cornelius
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These are some of the compliance-related stories that recently caught my attention.


The SEC Cancels Another Open Meeting: What Gives?
Broc Romanek
TheCorporateCounsel.net

The SEC has cancelled tomorrow’s open Commission meeting about proposing changes to its whistleblower office. I think this is the third cancelled open meeting in as many months. Does it matter? Not really. Is it worth blogging about? Probably not. Did I blog about it anyway? Yes.
Here’s a few thoughts:

https://www.thecorporatecounsel.net/blog/2019/10/the-sec-cancels-another-open-meeting-what-gives.html

Broken Windows: Remarks before the 51st Annual Institute on Securities Regulation
by Commissioner Hester M. Peirce

How can we make our enforcement program even better than it is? Over the past nearly two years, I have thought a lot about this question as I read the enforcement recommendations sent to my office and talk with our enforcement staff. The SEC’s enforcement program effectively serves American investors and the capital markets that underpin the broader economy. There is, however, always room for improvement. Therefore, in my remaining time with you this morning, I will suggest several avenues for improvement. Some of these themes are familiar, but they are ones that merit being raised with you. I welcome feedback on these suggestions from this room full of seasoned lawyers.

https://www.sec.gov/news/speech/peirce-broken-windows-51st-annual-institute-securities-regulation

The 10 Most Significant Changes in the Proposed Adviser Advertising Rule
Cipperman Compliance Services

The 10 Most Significant Changes in the Proposed Adviser Advertising Rule
1. Expanded Definition of “Advertisement”. The proposed rule applies to “any communication, disseminated by any means.”  This definition includes all digital and social media communications.

…

https://cipperman.com/2019/11/08/the-friday-list-the-10-most-significant-changes-in-the-proposed-adviser-advertising-rule/

Study: Second-Hand Reports More Reliable
by Matt Kelly
Radical Compliance

Some news that’s both useful to corporate compliance officers and totally relevant to our political drama in Washington: fresh research shows that whistleblower reports based on second-hand information tend to be more reliable than those from first-hand reporters. 
Moreover, second-hand reports are more likely to be about accounting or business integrity issues; and the more second-hand reports a company gets, the fewer lawsuits and smaller regulatory settlements it’s likely to pay out in future years. 

http://www.radicalcompliance.com/2019/11/01/study-second-hand-reports-more-reliable/

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