The EB-5 Immigrant Investor Program sounds like a scam so I’m not surprised to see it pop up in actual scams. The EB-5 program provides foreign investors who can demonstrate that their investments are creating jobs in this country with an expedited path to lawful permanent residency in the United States. EB-5 is not common … Read more »
Compliance Bricks and Mortar for September 5
These are some of the compliance-related stories that recently caught my attention. Fantasy Football: A Real and Present Danger to the Workplace? by Daniel Schwartz in Connecticut Employment Law Blog So to answer my own question in the title: No, fantasy football is not a critical threat to your business. But sometimes, fantasy football can … Read more »
Failing to Disclose Fees
The Securities and Exchange Commission has been focused on fees charged by investment advisers and fund managers. The latest target is Robare Group Ltd. based in Houston. The SEC alleges that the firm was receiving a fee from certain investments made for its clients but failed to properly disclose that it was receiving the fee. … Read more »
How Does the SEC Use Form PF in Adviser Exams?
You slave over Form PF trying to get the information demanded by the Securities and Exchange Commission. What happens to that data? The Dodd-Frank Wall Street Reform and Consumer Protection Act Section 404 directed the SEC to establish reporting requirements for investment advisers to private funds as necessary and appropriate in the public interest and … Read more »
Dog Days of Summer
It’s time for some vacation. I may lay around on the porch and not think much about compliance. Don’t expect any posts for the next few days. Read more »
Weekend Reading: Capital
In Capital in the Twenty-First Century, Thomas Piketty argues that if the rate of return on capital is persistently greater than the rate of economic growth this will cause wealth inequality to increase in the future. The theory is that wealth accumulated in the past grows more rapidly than output and wages. It’s a great … Read more »
Compliance Bricks and Mortar for August 22
These are some of the compliance related stories that recently caught my attention. Ebola tragedy is also a story of graft by Richard L. Cassin in the FCPA Blog One reason the fatality rate is so high — up to 90% in some regions, according to WHO — is because intensive care facilities are needed … Read more »
SEC’s Municipal Advisor Exam Initiative
The Securities and Exchange Commission announced a new examination initiative directed at newly regulated municipal advisors. The examinations are designed to establish a “presence” with the newly regulated municipal advisors. We’ve seen this blueprint before. It looks a lot like the presence exam initiative for newly registered private fund managers and the never before examined … Read more »
Another Tale of Golf Course Stock Tips Ending Up in a Sand Trap of Insider Trading
The Securities and Exchange Commission brought another insider trading case where the tips were allegedly traded on the golf course. “Country clubs or similar venues may give people a false sense of security that leads them to think they can get away with trading on unlawful stock tips,” said Paul G. Levenson, director of the … Read more »
The Stability of Prime Money Market Funds
I was critical of the Securities and Exchange Commission’s new rule on money market funds. To me it seemed like it was trying to fix a problem that didn’t exist, and in the process made things more complicated. For criticism to be correct, I need data. After review a paper on the Stability of Prime … Read more »