Doug Cornelius on compliance for private equity real estate
With the release of Episode VIII – The Last Jedi, I’m joining Tom Fox in tying compliance and the Star Wars franchise together in some posts this week. (I saw the movie last night, but I will refrain from revealing anything other than it was terrific.) One of the central themes of the Star Wars franchise is man … Read more »
I’m suffering from holiday creep and checking out the blog ahead of the actual holiday. Be compliant over the long weekend. Read more »
The Securities and Exchange Commission has been looking at fees and expenses at private equity funds for several years. Two years ago it brought a case against Kohlberg Kravis Roberts & Co. for misallocating more than $17 million in “broken deal” expenses to its private equity funds. An SEC investigation found that from 2006 to 2011, KKR … Read more »
Peter Sagan, for an historic third time in a row, earned the rainbow stripes of men’s road cycling world champion. And Chantal Blaak earned the rainbow stripes of women’s road cycling world champion. Over the weekend they competed on a thrilling course in Bergen, Norway. Salmon Hill, only 10 kilometers from the finish, splintered the … Read more »
An investment adviser should not buy positions on their own behalf shortly before recommending that position to its clients. Nor should the adviser make recommendations to buy when the adviser is selling in the adviser’s personal accounts. Mark A. Gomes was doing just that. The test case came against Capital Gains Research Bureau. The firm … Read more »
I saw this picture and it made think about compliance. At its most basic, the plane did land, the aviators did not die, and the aircraft carrier is still floating. But it was a not a compliant landing. The plane, the aircraft carrier, and the pilot are all damaged to some extent. That it was … Read more »
Professional cycling is not a mainstream sport in the U.S., so I would guess that few reading this story share my love of the Tour de France. (With the notable exception of Tom Fox.) The race has several different competitions going at the same time, with a confusing mix of skinny guys, tarted up with … Read more »
These are some of the compliance-related stories that recently caught my attention. SEC’s Clayton Vows to Do More Exams with Less Funding in AdvisorHub SEC Chairman Jay Clayton testified to Congress on Tuesday morning that the agency will increase its examinations of investment advisers by 20% in the current fiscal year and nudge the numbers … Read more »
The firing of FBI Director has set off a firestorm. Obviously, there is a great deal of partisan tilt to the action. I wanted to focus on the lesson we can see from a compliance perspective. It is an example of the need for independence of compliance and investigations. President Trump fired someone who was … Read more »
It was four years ago that David Blass mentioned that the SEC was taking a closer look at broker-dealer requirements for private fund managers in two contexts: selling interests in the funds and earning fees from the fund for capital transactions. Part of the problem is that the safe-harbors for selling your fund interests is … Read more »