These are my notes from the NRS Fall Compliance Conference. Who better to talk about supervision than Ted Urban himself. He was the general counsel and chief compliance officer. One of the firm’s registered representatives went rogue. He and other line supervisors were charged by the SEC for failure to supervise. Urban pushed for the … Read more »
Category: Conference Notes
SEC Examination and Enforcement Priorities
These are my notes from the NRS Fall Compliance Conference. John Walsh, Sutherland Karol Pollock, SEC Deputy Associate Regional Director (Exams) Karol outlined the examination process. 1. You get a phone call. But prior to the phone call, the examiners will have done some background research, looking at the firms ADV, public website and an … Read more »
Regulatory Roundtable at the NRS Compliance Conference
These are my notes from the NRS Fall Compliance Conference Lance Burkett, District Director for FINRA Michelle Wein Layne, Regional Director for the SEC Andrew Hartnett, Securities Commissioner in Missouri and representing NASAA Each panel member went through list of enforcement and risk priorities that are currently high on their organization’s list. NASAA Broker Dealer … Read more »
Beyond Compliance – Effectively Managing Risk
These are my live notes from PEI’s Private Fund Compliance Forum. They are likely to be incoherent and full of typos. Expert networks. The risk in using them came to the surface in 2010 when an insider trading case came out with and expert network involved in the distribution of information. Law enforcement has come … Read more »
Addressing Regulatory Challenges On The Horizon
These are my live notes from PEI’s Private Fund Compliance Forum. They are likely to be incoherent and full of typos. Panel Member: Jason Mulvihill, General Counsel, Private Equity Growth Capital Council Joel Wattenbarger, Partner, Ropes and Gray A bill has passed the House that would exempt private equity fund advisers from registration. It’s unlikely … Read more »
International Regulatory Landscape For Private Funds
These are my live notes from PEI’s Private Fund Compliance Forum. They are likely to be incoherent and full of typos. AIFMD is a difficult topic. Transitional regime. It’s just about over; it expires at the end of July 2014. They don’t work in France. They work well in the UK. Germany is in the … Read more »
Testing Your Compliance Program
These are my notes, live from the conference. One of the best tests is a mock exam. See how you stand up to simulated fire. It’s a good practice to see how people respond under the interview process from a regulator (or mock regulator). How often should you do a third party review? Annually is … Read more »
View from the SEC
These are my notes, live from the conference. Please excuse a more numerous supply of typos. Drew Bowden, the Director of the SEC’s Office of Compliance Inspections and Examinations (These are his views and not necessarily the views of the SEC. His speech is posted on the SEC website: Spreading Sunshine in Private Equity.) He … Read more »
Current Trends Impacting the Private Fund Compliance Community
These are my notes from this session at PEI’s Private Fund Compliance Forum. The SEC is developing an approach of zero tolerance for non-compliance. Private funds are challenging because there are some that have been registered fro many years and many that have only been registered for two years. The SEC is learning more about … Read more »
PERE CFO Forum 2013
I spent most of yesterday in New York at PERE’s CFO Forum. I came to speak about the evolution and revolution of regulation in the private equity real estate industry. I thought I would share a few items. The opening panel focused on the changing role of the Chief Financial Officer. A big change is … Read more »