IN addition to filing Form ADV with the SEC when they register with the Securities and Exchange Commission, private fund managers will also need to start filing Form PF next year. The amount of information required by Form PF is tiered. Advisers managing less than $150 million in private funds are not required to file, … Read more »
Halloween and Compliance
A compliance professional can turn the fun and chaos of Halloween into a boring night on the study of procedure. Here, I’ll prove it. Let’s start with costumes. Have you imposed a “no costume = no candy” rule. Perhaps you merely skimp on the older kids who have skimped on dressing up. If you, like … Read more »
Compliance Bits and Pieces for October 28
These are some compliance-related stories that caught my attention recently: The Role of Compliance and Ethics in Risk Management by Bruce Carton in Compliance Week’s Enforcement Action Carlo V. di Florio, director of the SEC’s office of compliance inspections and examinations, recently spoke at the National Society of Compliance Professionals’ National Meeting held in Baltimore, … Read more »
New Financial Legislation Takes Another Step
Four bills made their way through the Capital Markets and Government Sponsored Enterprises Subcommittee of the House Financial Services Committee last week and this week were approved by the full Financial Services Committee . Private Company Flexibility and Growth Act (H.R. 2167) Access to Capital for Job Creators Act (H.R. 2940) Entrepreneur Access to Capital Act (H.R. 2930) The … Read more »
The Leaves Say You Will Go Free
The insider trading case against Raj Rajaratnam seemed very tight. The prosecutors had him on tape discussing the inside information from wiretaps. So why did he fight his insider trading charges and get a lesser sentence than the 11 years that was handed down last week? Ola Leaves. Suketu Mehta in the Daily Beast discussed … Read more »
Outsourcing Compliance and the CCO
One of the requirements of registration as a registered investment adviser is the appointment of a Chief Compliance Officer and the establishment of a formal compliance program. The SEC stated that a firm need not hire a new person to be the CCO. However, there will be a substantial time commitment. You can spread some … Read more »
Compliance Bits and Pieces for October 21
These are some compliance-related stories that recently caught my attention: The Abacus Sign by Felix Salmon It’s funny, on the sign — something true, and accurate, and touching, and grammatical, and far too long to be a slogan, and gloriously bereft of punctuation, and ending even more gloriously in a mildly archaic preposition. Friedersdorf has … Read more »
Occupy the SEC
I will admit that I have been personally dismissive of the Occupy Wall Street movement and the splinter group of Occupy Boston that I pass by on the way to the office. Yesterday’s post on Occupy LEGO Land was an example. They lack a message and I personally think most of their message are off … Read more »
Occupy LEGO Land
As the #OccupyWallStreet protests grew, it was inevitable that the movement would spread in unusual ways. That includes plastic toys. “We must not be LEGO ‘lands’ — We must be a LEGO NATION.” #OccupyLegoLand is a Facebook Fan Page that gives voice to LEGO minifigures. Like Occupy Wall Street, they are battling on many fronts: … Read more »
I Wonder if We Will Laugh at his Phone When He Gets Out?
You could watch the movie Wall Street and many things may still ring true. Of course its the 1980s, so the clothes and the women’s hair stick out. But the icon is the big brick cell phone. It was huge and expensive for its time. And all it did was makes phone calls. It was … Read more »