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Doug Cornelius on compliance for private equity real estate

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Author: Doug Cornelius

You can find out more about Doug on the About Doug page
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The One with the Line That Goes Straight Up and Right

Posted on May 1, 2026April 30, 2026 by Doug Cornelius

Would you invest in a company that beat the S&P 500 with 19% returns over the last five years? Sounds interesting, sure… But what if the chart of performance looked like this: That is a really straight line. Just one little flat period in December 2022. No, thank you. That’s a fraud. I saw this…

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The One with the Crypto Paying for a Mega-Shilling Package

Posted on April 22, 2026April 21, 2026 by Doug Cornelius

It caught my by surprise that the Securities and Exchange Commission brought a case against a crypto-crap company this week. After the SEC published its “clarification” on the application of federal securities laws to crypto assets I thought we wouldn’t see a crypto case for a long time. I guess the SEC found the actions…

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The Performance of the SEC in 2025

Posted on April 14, 2026April 8, 2026 by Doug Cornelius

The other half of the Securities and Exchange Commission budget request for 2027 is a report on its performance in fiscal year 2025. How did the SEC perform in enforcement actions? The SEC was off its game. The 85% metric was the lowest in years. I believe this number might dip some more with the…

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More on the Downsizing of the SEC

Posted on April 13, 2026April 8, 2026 by Doug Cornelius

I wrote last week how the Securities and Exchange Commission had 18% of its staff depart in fiscal year 2025 thanks to the DOGE efforts to reduce the size of the federal workforce. For Fiscal Year 2027, the SEC is proposing to reduce its budget by another 11%. However, the SEC is proposing to add…

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SEC Enforcement Results for FY 2025

Posted on April 9, 2026April 8, 2026 by Doug Cornelius

This is press release that would not have been written by judge Margaret Ryan if she was still serving as the Director of Enforcement. She only lasted six months with the rapid down-sizing and lack of enforcement at the Securities and Exchange Commission. I was stunned to see the SEC attack its prior stewardship in…

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Proposed Fundamental Reforms to AML Programs

Posted on April 8, 2026April 7, 2026 by Doug Cornelius

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a proposed rule intended to “fundamentally reform” financial institutions’ anti-money laundering and countering the financing of terrorism programs under the Bank Secrecy Act. The three key changes according to FinCEN: Those all sound more like goals than changes. It doesn’t tell us what the…

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Is It a Truck or a Security?

Posted on April 7, 2026April 6, 2026 by Doug Cornelius

A trucking company is looking for capital. It needs trailers and trucks. You give the company money to buy the truck on your behalf and the trucking company leases it back to you. The truck company will arrange the purchase and financing. It will find a driver. It will take care of licensing, registration, insurance,…

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The One with Low IQ from Pet IQ

Posted on April 6, 2026April 6, 2026 by Doug Cornelius

You’re senior management of a public company. You just made a million dollar bonus for performance. You get paid $735,000 if the company is sold. You’ve got 150,000 shares of company stock that’ll be worth over $4 million. You’re in the process of selling the company. Do you tell your wife and best friend about…

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The Downsizing of the SEC

Posted on April 2, 2026April 2, 2026 by Doug Cornelius

In fiscal year 2025, the Securities and Exchange Commission had a departure of 18% of its employees. The SEC’s Division of Investment Management lost 24% of its staff during fiscal year 2025. What is the effect of the departure? The GAO had interviews with several dozen SEC employees. We’ll see how this affects the SEC….

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When “Today” Is Not all of “Today”

Posted on April 1, 2026March 31, 2026 by Doug Cornelius

“BREAKING NEWS THE [Politician] PORTFOLIO ON DUB SOARED +7.77% TODAY, HITTING A NEW ALL TIME HIGH OF +120%” This proposed marketing blurb was submitted at 2:31 pm., before the markets has closed for the day. As the Massachusetts Secretary of State pointed out, that is not performance for the day. It’s only performance for part…

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