The Wall Street Reform and Consumer Protection Act of 2009, passed by the House on December 11, 2009 is over 1300 pages long. The Restoring American Financial Stability Act of 2010, passed by the Senate on May 20, 2010, is over 1600 pages long. You have lots of reading to figure out the differences between … Read more »
Category: Compliance Programs
Compliance and the Desert Island
A compliance challenge is seeing below the surface. The big danger comes from what you don’t know that you don’t know. I thought this cartoon was right on target Image is from XKCD Read more »
The 2010 OCEG GRC Achievement Awards Presentation
The Open Compliance and Ethics Group will recognize the great strides that many organizations have made in improving and integrating their approaches to governance, risk management, and compliance. The winners were: Best Buy – Ethics blog for employees Capital One – GRC implementation Carnival Corporation – Integrated approach to GRC Management Direct TV- Embedding spreadsheet … Read more »
Full Text of the Dodd Bill
The Restoring American Financial Stability Act of 2010 has been published in the form passed by the Senate last night. Full Text of S.3217 in PDF (its a big file, 1566 pages) Read more »
Cash, Ash or Crash – Nobody Rides for Free
Iceland has been a sources of trouble. In October of 2008 their banking system crashed after ill-advised over-expansion. Proportionally, Iceland’s financial meltdown made the US failure look quaint. The three biggest banks in Iceland, a country of only 310,000, made loans totaling over 850% of Iceland’s Gross Domestic Product. In April, Iceland’s Eyjafjallajökull volcano erupted … Read more »
Trust and Compliance
To some extent, compliance programs are about the opposite of trust. A compliance professional wants to check on the status of a person’s actions to make sure rules are not being broken. Theoretically, you wouldn’t need to check on the status if you trusted that the person would not break the rules. There are two … Read more »
You know you’ve failed as a CCO when you get barred by FINRA
The Financial Industry Regulatory Authority permanently barred Tod Bretton, former chief compliance officer and head trader for Prestige Financial Center, Inc. “FINRA found that, from at least September 2006 through June 2009, Bretton, working from the firm’s New York office, engaged in a fraudulent trading scheme in which he took advantage of customers placing large … Read more »
Taxonomy and Compliance
Compliance often has to deal with a great big piles of data. When tackling a big pile of data, it helps to organize the data into a taxonomy. The taxonomy helps with analysis. Of course, just by choosing the nodes in the taxonomy you are influencing the view of the data. I was struck by … Read more »
Revisions to U.S. Sentencing Guidelines for Compliance Programs
At their April meeting, the U.S. Sentencing Commission voted to adopt changes to Chapter 8 of the Sentencing Guidelines Manual. That chapter defines an effective compliance and ethics program and has been one of the sacred texts of the compliance profession. Here is my summary of the changes: Changes to §8B2.1 In defining an Effective … Read more »
Incentives, Productivity and NUMMI
I recently listened to a great show from This American Life. They covered the story of New United Motor Manufacturing Inc. (NUMMI). General Motors and Toyota opened NUMMI in 1984 as a joint venture so Toyota could start building cars in the US. Toyota showed GM the secrets of its production system and how Toyota … Read more »