Ladislav “Larry” Schvacho purchased approximately 72,000 shares of Comsys IT Partners, Inc. stock between November 9, 2009 and February 1, 2010. On February 2, 2010, Manpower, Inc. and Comsys publicly announced a merger, resulting in a 31% percent increase in the share price of Comsys from its prior day’s close. As a result of his trading … Read more »
Will They Contest the Freeze?
It looks like the SEC has stopped a big insider trading scheme. At least for the moment. But can the SEC find the evidence to prove its suspicions about Well Advantage? I doubt it. The case involves trading in shares in advance of the announced $15 billion acquisition of a Canadian oil producer, Nexen, by … Read more »
Is Decimalization Good or Bad?
Although commentators have been viewing the Jumpstart Our Business Startups Act as a rollback of 2010’s Dodd-Frank financial reform, it’s been showing itself as much more of an attack on the earlier Sarbanes-Oxley Act. The latest attack is a required report on a possible rollback of decimalization. A decade ago, the SEC and the exchanges … Read more »

Veni… Vidi… Wiggins!
I would guess that most of you reading this story do not share my love of the Tour de France. (Except Tom Fox.) The race can be a confusing mix of skinny guys, tarted up with sponsors like a NASCAR racer, with hard to pronounce names, following tactics unusual outside of cycling. But I since … Read more »

Compliance Bits and Pieces For July 20
These are some stories that recently caught my attention: Inside Straight: The Shoemaker’s Children by Mark Herrmann in Above the Law I recently heard a law firm presentation describing the UK Bribery Act along the lines I just laid out. A member of the audience asked the obvious question: “If bribery of anyone — including … Read more »
Real Estate Fund CCO Forum
NEW YORK We are starting a new forum for real estate fund compliance managers in New York. The first meeting is noon on July 24 near Chelsea Market. BOSTON The Boston group of real estate fund compliance professionals will meet again in September after taking the summer off. ABOUT The groups meet to discuss the … Read more »
OFAC and Private Funds
An SEC-registered investment adviser entered into a settlement agreement with the U.S. Treasury Department’s Office of Foreign Assets Control for allegedly failing to maintain a compliance program. The problem was triggered when the adviser’s foreign affiliate caused one of its clients to invest in a Cayman Islands fund that appeared on OFAC’s list of Specially … Read more »
This is Not Compliance
UPDATE (9/10/2019): The CEO/CCO in question contacted me and told me her side of the story with regards to the SEC. According to her, an investor sued based on the SEC case and the charges were largely dismissed. As I point out and have now highlighted, I relied on the order to illustrate what the … Read more »
What Does FINRA Think About Crowdfunding?
The crowdfunding provisions in Title III of the JOBS Act provide an exemption from registration under the Securities Act of 1933 for securities offered by through crowdfunding, provided the numerous requirements are met. An intermediary that seeks to engage in crowdfunding must be registered as a broker-dealer or a funding portal. I expect many people … Read more »
Compliance Bits and Pieces for July 13
These are some recent compliance-related stories that caught my eye. How To Define Your Terms In 300 Pages by Theo Francis in NPR’s Planet Money In Tuesday’s show, economist Luigi Zingales warned that massive, overly complicated laws and regulations go a long way toward undermining public trust in the government. They leave only lobbyists and … Read more »