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 »
Category: Compliance Programs
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 »
Making the Case for Compliance at Private Companies
More focus has been aimed at the need for compliance programs at public companies. Of course, that focus has been largely drive by the requirements of Sarbanes-Oxley. The other focus comes from highly regulated industries like financial services that require compliance programs. That doesn’t mean that private companies can ignore compliance. There are many more … Read more »
Financial Overhaul Moves Forward
With the health care reform now out of the hands of Congress, there is now movement with financial overhaul. Senator Dodd introduced the Restoring American Financial Stability Act of 2010 last week without a Republican co-sponsor [Dodd Goes Solo]. Instead plugging in amendments, the Senate Banking Committee voted on straight party lines to advance the … Read more »
World’s Most Ethical Companies 2010 Edition
Ethisphere Institute just announced its list of the World’s Most Ethical Companies for 2010. Of the 100 companies on their list, 26 are new to the list. The sole winner for the real estate industry is Jones Lang LaSalle. For the financial services industry there were three companies: American Express, The Hartford and The Principal Financial … Read more »
SEC Warns Firms on Muni Pay-to-Play Rules
While sources are wallowing in the exposure of a political figure in a “pay to play” scandal, I thought there might be some lessons for other investment managers as states and perhaps the SEC roll out limitations on political contributions. The original story seemed mildly interesting. The SEC warned firms that municipal securities rules prohibiting … Read more »
Blogoversary!
Instead of substantive information, today’s post focuses on me and this website. Compliance Building went public on February 12, 2009. Since then, it looks like I have managed to get out a blog post every business day. Sometimes, more than one. Thanks for reading. If you haven’t done so already, you can subscribe and have … Read more »
Proposed Amendments to Sentencing Guidelines
The United States Sentencing Commission has proposed some changes to the Federal Sentencing Guidelines. Of the eight changes, one should catch the eye of compliance professionals. There is a proposed amendment to Chapter Eight of the Guidelines Manual regarding the sentencing of organizations, including proposed changes to §8B2.1 (Effective Compliance and Ethics Program) and §8D1.4 … Read more »
Dan Pink on the Surprising Science of Motivation
Dan Pink, at TED Global in July 2009, broke tasks, performance and rewards for performance into two groups. With complex problems, financial rewards do not impact performance and seem to dull creativity. Actually, they seem to deter performance. With a simple problem and a simple set of rules, then contingent motivations for performance (like financial … Read more »
Clothing Drive
This ad induced a huge spit take. I had to wipe off my monitor. Plenty to learn in this video about incentives and unintended outcomes. You can see the obvious HR issues. Bud Light | “Clothing Drive” commercial on YouTube Read more »