The Securities and Exchange Commission put the financial sector in a tizzy when it announced a sweep exam addressing cybersecurity last April. Along with the announcement came a detailed document request list that would make most compliance officers’ heads spin. The problem with the cybersecurity sweep is that it seems to be coming from the … Read more »
Compliance and the Super Bowl
As a long time Patriots fan, it’s a great morning. But the Patriots and the NFL were not without compliance failures. Clearly, something went wrong with the Patriots’ footballs in the Indianapolis game. I keep hearing conflicting reports and the investigation is not complete so it’s hard for me to draw any conclusions. But the … Read more »
Compliance Bricks and Mortar for January 30
I have finally dug myself out from the 2+ feet of snow that buried me this week. These compliance-related stories caught my eye in between snow shoveling sessions. SEC Co-Chief of Division of Enforcement’s Asset Management Unit Identifies 2015 Exam Priorities for Hedge and Private Equity Funds in the National Law Review On November 18, … Read more »
Compliance Brought to You by Juno
The Massachusetts Governor declared a travel ban and public transportation has been stopped. That definitely makes it a stay-at-home day for me. I’ll be out shoveling instead of writing about compliance today. Read more »
What’s in your Wallet? Insider Trading
It’s clearly insider when a company’s high-level executive trades on pending earnings data not yet released to the public. It’s clearly not insider trading when you count cars in a retailer’s parking lot to get insight to sales. A recent SEC case falls somewhere in the middle. The Securities and Exchange Commission brought charges against … Read more »
Compliance Bricks and Mortar for January 23
These are some of the compliance-related stories that recently caught my attention. Equity Crowdfunding: A Market for Lemons? by Darian M. Ibrahim in the CLS Blue Sky Blog Before reaching the more difficult Title III, I reveal that the less-radical Title II, which allows general solicitation of accredited investors, seems to have proven successful for … Read more »
Massachusetts Adopts Crowdfunding
Add Massachusetts to the growing list of states that are sidestepping the unusable federal crowdfunding alternative. “The Crowdfunding Exemption is designed to foster job creation by helping small and early-stage Massachusetts companies find investors and gain greater access to capital with fewer restrictions. The exemption is also intended to provide necessary investor protections by requiring … Read more »
Preparation for SEC Examinations
Ascendent Compliance put together a presentation on Preparation for SEC Examinations. Last year the SEC examined 9% of advisers which represent 25% of the RAUM. Of those exams, 87% had deficiencies, 25% had significant findings, and 14% were referred to enforcement. The SEC has implemented a new telephone assessment for offsite remote exams. The examiners … Read more »
Martin Luther King Jr. Day
It’s the third Monday of January, so that means a day off to celebrate the Birthday of Martin Luther King, Jr. It was officially observed in all 50 states for the first time in 2000. President Ronald Reagan signed a bill creating the federal holiday to honor King in 1983. How to celebrate? Read more »
Weekend Riding – Facing the Cold
That’s me, bundled up for my first bike ride of 2015 on Saturday. I was going to ride first thing in the morning, but shied away when I saw a 9 degree reading on the thermometer. I waited for the balmy afternoon temperature of 22 degrees before enduring a 15 mile ride. Why ride? I’m … Read more »