These are some compliance related stories that recently caught my attention. Are Girl Scout Cookies Evil? by Chris MacDonald in the Business Ethics Blog Well, apparently nothing is safe from criticism. Girl Guide cookies, as it turns out, are under attack for being made with palm oil, a tropical oil the production of which has … Read more »
Raj is Guilty. Nobody Is Surprised.
If you read about the evidence, you can’t really be surprised that Raj Rajaratnam was found guilty of insider trading. That he was found guilty on all counts was mildly interesting, but not much. We may get some interesting new legal developments in insider trading law from the appellate decisions. But probably not. The case … Read more »
The SEC Is Making it Harder for Investment Advisers to Earn Performance Fees
The Securities and Exchange Commission is proposing to raise the dollar thresholds for someone to be considered a “qualified client.” The definition of a qualified client is set out in Rule 205-3. This is an exemption to the Section 205(a)(1) general prohibition on performance fees. Section 205(e) grants the SEC the power to create an … Read more »
The House Financial Services Committee Wants to be Your Friend
Congressman Bachus must have let one of his grandkids near the computer. The House Committee on Financial Services, of which Congressman Bachus is the chairman, has jumped into the world of social media. They have a Twitter feed, a YouTube Channel, a Facebook page and a blog: The Bottom Line. Even though the SEC has … Read more »
Are Real Estate Fund Managers Registered with the SEC?
Last year, I looked a the top 30 real estate private equity fund managers to see which are already registered with the SEC. The 2011 version of the PERE 30 just came out, so I decided to look at the list again. (Disclosure: my company is on the list.) It was mostly re-shuffling, but three … Read more »
Compliance Bits and Pieces for May 6
Here are some compliance-related stories that recently caught my eye: Investing in an ethical corporate culture by Aarti Maharaj in Corporate Secretary Companies are starting to distinguish between non-financial and financial risks in order to continue improving their overall governance and business structures. But non-financial risks, such as ethics, still don’t get the attention they … Read more »
Near Misses, Catastrophes, and Compliance
The theme of the April edition of the Harvard Business Review is “Failure.” As scary as that term is in the world of compliance, “catastrophe” is even scarier. That means that the failure resulted is real, significant damage. But you can learn from failures. You can especially learn from others’ failures. In How to Avoid … Read more »
Failure and Compliance
The theme of the April edition of the Harvard Business Review is “Failure.” That’s a scary term in the world of compliance. Generally, that means you’ve got government regulators or enforcement personnel sitting in your offices. And they are not happy. Failure and compliance can mean disciplinary action, fines, or jail time. But you can … Read more »
The Monstrous Size of Dodd-Frank
“What is 20 times taller than the Statue of Liberty, 15 times longer than “Moby Dick” and would take the average reader more than a month to read, even if you hunkered down with it for 40 hours a week?” If you’ve been Dodd-Frank’ed, you know the answer. The last round of financial overhaul was … Read more »
Massachusetts Is Looking to Dodd-Frank Investment Advisers and Fund Managers
Just to keep you on your toes if you have less than $150 million under management, states are now filling in the gaps left by Dodd-Frank. If you are under that threshold, you lose the ability to register with SEC and now have to look to at being regulated at the state level. Massachusetts used … Read more »