The Overbooking Failure

Air travel has gotten has gotten less pleasant over the years. The TSA makes it unpleasant to get to the plane. Then the plane themselves have reduced passenger room. United took the unpleasantness to an even lower level when it forcibly removed a passenger from an overbooked flight. “Flight 3411 from Chicago to Louisville was … Read more »

The Fearless Girl

The sculpture, titled “The Fearless Girl,” was made by Kristen Visbal and photographed by Federica Valabrega. State Street Global Advisors conspired in the middle of the night to drop a statue in Bowling Green Park of a girl facing off against the famous Wall Street Charging Bull. It’s part of a campaign by SSGA to … Read more »

Congress Disapproving The SEC Rule That Congress Made The SEC Make

Dodd-Frank made the Securities and Exchange Commission create a rule on the disclosure of payments by resource extraction issuers. The SEC finally got the rule out this fall. Now Congress is threatening to abolish the rule. Section 1504 of the Dodd-Frank Act directed the Securities and Exchange Commission to “issue final rules that require each … Read more »

The Trump Organization’s Compliance Program Begins

Last week, the Trump Organization kicked off its compliance program by making two appointments. Bobby Burchfield will be independent ethics adviser. He’ll be responsible for signing off on transactions that could raise ethics or conflicts of interest concerns. George Sorial will become chief compliance counsel. In the January 11 press conference, Sheri Dillon announced: [T]o … Read more »

CCO Liability for False Statements on Form ADV

Susan Diamond was Chief Compliance Officer of Saddle River Advisors. Now, Ms. Diamond is out of pocket for a $15,000 penalty and is subject to a nine-month suspension from being associated with any investment adviser or other financial services firms. After the suspension, she will be prohibited from acting in the securities industry in certain managerial … Read more »

The SEC Really Means It About Pretaliation Severance Agreements

In case you were not clear that the Securities and Exchange Commission is serious about enforcing Rule 21F-17, BlackRock is the latest to run the perp walk. The SEC accused the money management giant of improperly using separation agreements that forced employees to waive their ability to obtain whistleblower awards. The SEC adopted Rule 21F-17, which provides in … Read more »

Draining the Swamp?

One of the rallying cries for President-elect Trump was to drain the swamp of corruption. Compliance professionals could think of many things that could happen to remove conflicts or the appearance of conflicts. Personally, as a compliance professional and a voter, I was disappointed to learn that Hillary Clinton did a poor job of walling … Read more »