Although commentators have been viewing the Jumpstart Our Business Startups Act as a rollback of 2010’s Dodd-Frank financial reform, it’s been showing itself as much more of an attack on the earlier Sarbanes-Oxley Act. The latest attack is a required report on a possible rollback of decimalization. A decade ago, the SEC and the exchanges … Read more »
Category: Compliance Programs
Veni… Vidi… Wiggins!
I would guess that most of you reading this story do not share my love of the Tour de France. (Except Tom Fox.) The race can be a confusing mix of skinny guys, tarted up with sponsors like a NASCAR racer, with hard to pronounce names, following tactics unusual outside of cycling. But I since … Read more »
Real Estate Fund CCO Forum
NEW YORK We are starting a new forum for real estate fund compliance managers in New York. The first meeting is noon on July 24 near Chelsea Market. BOSTON The Boston group of real estate fund compliance professionals will meet again in September after taking the summer off. ABOUT The groups meet to discuss the … Read more »
This is Not Compliance
UPDATE (9/10/2019): The CEO/CCO in question contacted me and told me her side of the story with regards to the SEC. According to her, an investor sued based on the SEC case and the charges were largely dismissed. As I point out and have now highlighted, I relied on the order to illustrate what the … Read more »
The US Private Real Estate Fund Compliance Guide
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 requires US advisers to private funds with at least $150 million in assets under management to register with the Securities and Exchange Commission as investment adviser. Venture capital fund managers are explicitly exempted from many aspects of registration. Real estate funds are not explicitly … Read more »
Compliance Bits and Pieces for June 1
These are some compliance related stories that recently caught my attention. The Symbolism of the Bull and the Bear by Amy Farber, New York Fed Research Library The term “bear” dates back to 1709, when it was used as shorthand for the bearskin jobber occupation. The title “bearskin jobber” originates from a proverb highlighting the … Read more »
What SEC Registration Means for Hedge Fund Advisers
Earlier this month Norm Champ, Deputy Director, Office of Compliance Inspections and Examinations at the SEC, addressed the New York City Bar and gave a preview of what the SEC has in mind for private fund advisers. I thought this tied nicely with the speech given by Norm’s boss, Carlo V. di Florio, at PEI’s … Read more »
Complexity
Does your policy look something like this sign? This is a real sign that was posted near schools on Bogie Lake Road in White Lake, Michigan. The speed limit is normally 45 on that street, except during these half hour periods on school days when the speed limit drops down to 25, except the first … Read more »
It’s Compliance and Ethics Week
Compliance Bits and Pieces for April 6
Earl Scruggs: Banjo, Bluegrass and the Fight against Corruption and Bribery by Tom Fox So what is the lesson of Earl Scruggs for the compliance practitioner? It is this, even if you develop a completely new style that makes you one of the foremost experts in an area, you can still evolve. Further, the style … Read more »