Doug Cornelius on compliance for private equity real estate
I’ve been critical before of the Securities and Exchange Commission’s Attack on May. Personally, I’ve always viewed “may” as a permissive position when it comes to disclosure. The SEC thinks its completely inadequate. The SEC view is that if an investment adviser always takes the fee or usually take the fee, “may” is inadequate. How often … Read more »
According to SEC’s complaint against Strong Investment Management and its owner, Joseph Bronson, for more than four years, Bronson traded securities in Strong’s omnibus account but delayed allocating the securities to specific client accounts until he had observed the securities’ performance over the course of the day. This allowed Bronson to harvest substantial profits at his … Read more »
Redwood Wealth got into trouble with the Securities and Exchange Commission for missing the custody compliance issues related to an investment program. Redwood Wealth had some of its advisory clients invest in an affiliated mortgage company. Obviously, there are some disclosure items. Presumably, Redwood Wealth took take of that adequately. The investment was structured as … Read more »
You hate to see a peer break bad. The Securities and Exchange Commission charged Jose Luis Casero Sanchez, a former Senior Compliance Analyst who worked in the Warsaw, Poland office of an international investment bank, with insider trading involving at least 45 corporate events with the investment bank’s clients. Ugh. He’s giving compliance a bad … Read more »
Back blogging on a regular basis for the week. Hoping to keep it up. These are some other compliance-related stories that recently caught my attention. The Scammer Threat to Your HotlineBy Ted BanksSCCE’s The Compliance & Ethics Blog Several of the companies that originally received the fake report have now received a message from one … Read more »
I’ve complained about the Securities and Exchange Commission focusing on the use of the word “may” in disclosures. I’ve typically expected “may” to offer some optionality for the adviser. The SEC has found it inadequate in several instances. We can agree to disagree. I just came across a case in which I agree that the … Read more »
Matthew Panuwat was a business development executive at Medivation, an oncology-focused biopharmaceutical company. Panuwat learned from Medivation’s CEO that the company expected to be acquired by a major pharmaceutical company, Pfizer, within a few days, at a premium to the then-market price. Panuwat did not trade in Medivation securities. Rather, within minutes of hearing the … Read more »
The Securities and Exchange Commission sanctioned three broker-dealer/investment advisers for failures in their cybersecurity policies and procedures that resulted in email account takeovers. Each of the firms was using cloud-based email accounts that were hacked. The three firms had not mandated multi-factor authentication for access to the email accounts. The SEC claimed failure under Rule … Read more »
Minnesota residents Jason Dodd Bullard and Angela Romero-Bullard raised millions from investors, mostly friends and family, and said it would be used to trade foreign currencies. Instead, the Securities and Exchange Commission claims that the two diverted the money to other uses and falsified account statements. In the classic Ponzi scheme fashion, they used new … Read more »
Return Time. Back to the office. Back to school for the kids. And back to blogging more regularly. These are some of the compliance-related stories that recently caught my attention. In Silicon Valley, Criminal Prosecutors See No Evilby David StretifeldThe New York Times Federal prosecutors in Northern California took on only 57 white-collar crime cases … Read more »