On the front page of today’s Wall Street Journal is story about one of the fallouts from Goldman Sachs’ recent problems with the SEC: George Carlin Never Would’ve Cut It at the New Goldman Sachs. One of the most sensational bits of Goldman Sachs fiasco was an email from a Goldman executive “[B]oy that, timberwolf … Read more »
Category: Compliance Programs
Do Prosecutions Stop Insider Trading?
We generally assume that the prosecution of crime acts as a deterrence to others who may think about committing the crime. One of the key factors in fraud is opportunity. If the wrongdoer thinks they can not get away with the violation, they are less likely to commit the violation. At least that is the … Read more »
Compliance Bits and Pieces – July 2
Early this week, some people expected fireworks to come from the Free Enterprise v. PCAOB decision. Instead, we got cheap package of sparklers. Fun for a few minutes, but unlikely to leave much of a lasting impression. Here are some interesting compliance-related stories from the past week. SEC Statement on Supreme Court’s Decision in FEF … Read more »
Cheap Sunglasses and Compliance
Can cheap sunglasses affect your ethical behavior? An important part of a compliance program is monitoring and improving the ethical behavior of your workforce. I’m always intrigued by ethics experiments. Francesca Gino of Chapel Hill, Michael Norton of Harvard Business School, and Dan Ariely of Duke tested the effect of wearing knock-off designer sunglasses. They … Read more »
Should Private Funds Have more than $10 Billion?
The current draft of the Dodd-Frank Wall Street Reform and Consumer Protection Act has a surprise in it for big hedge funds. By “surprise” I mean tax. Title XVI: Financial Crisis Special Assessment has a $19 billion fee ready to be assessed against financial companies institutions with more than $50 billion in assets and hedge … Read more »
GRC Professional Survey
The folks at the Open Compliance & Ethics Group have been developing a professional education and certification program for governance, risk management and compliance professionals. Basically, it’s a program that helps to build on existing credentials and “round out” an executive’s skills so that they are more effective at integrating all of these processes (e.g., … Read more »
Final Text of the Private Fund Investment Advisers Registration Act of 2010
There is a lot happening in the Dodd-Frank Wall Street Reform and Consumer Protection Act. (Yes, that appears to be the agreed upon name of the financial reform bill.) I’m most interested in its Title IV: Private Fund Investment Advisers Registration Act of 2010(.pdf). The act will remove the current exemption from SEC registration for … Read more »
Compliance Bits and Pieces for June 25
Here are some recent stories that I found interesting: Officially our best-ever cease and desist from ThinkGeek But what makes this cease and desist so very, very special is that it’s for a fake product we launched for April Fool’s day. No Fund for States to Oversee Advisers? by Mark J. Astarita, Esq. on SECLaw.com … Read more »
Compliance and Humor
At the Compliance Week 2010 Conference I was surprised to discover that the improv comedy group, Second City, had dived into the world of compliance and ethics awareness. They debuted three of their awareness videos during the conference keynotes. They are now available on their Real Biz Shorts website: Cracking the Code Up-Setting a Good … Read more »
Getting Cleaned by Oil Spill Stock Scams
I doubt you have missed the news about the oil spill mess in the Gulf of Mexico. The scammers have clearly noticed and sense an opportunity to make a quick buck. Some companies may issue press releases, or send unsolicited faxes or spam emails that might include: Claims to have products or technologies that are … Read more »