Doug Cornelius on compliance for private equity real estate
These are some of the compliance-related stories that recently caught my attention. The Cost to Retail Investors and Public Markets of “Harmonizing” Securities Offering Exemptions By Erik F. GerdingThe CLS Blue Sky Blog Investing in private securities would pose considerable additional risks for retail investors, relative to investing in public securities, and existing research suggests … Read more »
We all have hobbies. Me?: Cycling, reading, kayaking. Some people have finance as a hobby. Sure you can spout off about finance. But, eventually you step into the world of financial regulation if your spouting off turns into financial advice. Marcos Tamayo of Las Vegas was an airline baggage handler by day and, apparently, became … Read more »
The Security and Exchange Commission filed a complaint alleges that Mark Ray, a Denver resident, was the mastermind of a scheme for the purported purchase and immediate resale of large numbers of cattle. I don’t recall cattle showing up in the definition of a “security.” The first part of the scheme is labeled a Ponzi … Read more »
The Securities and Exchange Commission charged PricewaterhouseCoopers LLP and one of its partners with violating auditor independence rules for running a project to upgrade the client’s GRC software while also doing its audit work. Using the “one” in the title is deceiving. This is the third auditor independence case that the Securities and Exchange Commission … Read more »
These are some of the compliance-related stories that recently caught my attention. Oversight of the Securities and Exchange Commission: Wall Street’s Cop on the Beat The SEC’s mission is to: (1) protect investors; (2) maintain fair, orderly, and efficient markets; and (3) facilitate capital formation. The SEC oversees over 27,000 market participants, including investment advisers, … Read more »
On September 17, 2019, the U.S. Department of the Treasury issued proposed regulations to implement the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). The proposed regulations would expands the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) to review foreign investments and mitigate any potential national security concerns regarding … Read more »
I don’t like compliance officers being dragged into enforcement actions. If they are involved in the wrongdoing or are just a wholesale failure at compliance, I understand why. Elliot Daniloff a/k/a Ilya Olegovich Danilov was the chief compliance officer of ED Capital Management, LLC, and its managing member and owner. The firm was a registered … Read more »
These are some of the compliance-related stories that recently caught my attention. How to Ace Compliance Interviews: Advice for the Next Generation of Compliance Officers by Mary ShirleyCorporate Compliance Insights Your hard work tailoring applications to the job and company has paid off and you’ve been invited to interview. Congratulations on being shortlisted! How do you … Read more »
Yes. Perhaps it’s useful to have some data behind that “yes.” Stephen G. Dimmock, William Christopher Gerken, and Nathaniel Graham looked at 477 financial firm mergers between 1999 and 2011 with multiple branch offices in overlapping cities. They used Form U4 to identify mass transfers of employees in the same city. They also used the … Read more »
Dodd-Frank created a new legal definition for a “private fund” as pooled investment vehicles that are excluded from the definition of “investment company” under the Investment Company Act of 1940 by section 3(c)(1) or 3(c)(7) of that Act. Real estate funds managers have used these standards because they are bright-line tests. It also skirts around … Read more »