Doug Cornelius on compliance for private equity real estate
Immigration and citizenship employee compliance requirements are fairly straightforward, although awkward. You can’t usually ask whether or not a job applicant is a United States citizen before making an offer of employment. But you do need to verify the identity and employment eligibility of all employees, by completing the Employment Eligibility Verification (I-9) Form, and … Read more »
After a long weekend, and perhaps a vacation, compliance professionals are coming back into the office with 2018 on the calendar. It’s a clean slate. The possibilities are endless. Where to start? I don’t have the answer. There is so much to get done and so many challenges ahead. No organization has has the same … Read more »
A few months ago, Securities and Exchange Commission Chairman Jay Clayton stated that the SEC had been hard at work on developing its rule-making agenda for the upcoming year. In the coming weeks and months, I expect the SEC’s near-term rulemaking objectives to be fully reflected in our upcoming Regulatory Flexibility Act Agenda. As a … Read more »
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 »