The SEC released the final version of its new custody rule (.pdf). The Commissioners had announced their approval of the rule on December 17 and then released the final text on December 30. The rule goes into effect 60 days after publication in the Federal Register. The amendments are designed to provide additional safeguards under … Read more »
Whales and Compliance
I was surprised to be thinking about compliance while I was reading about whales. Sure, I eat, drink and sleep compliance. But there are some lessons that compliance professionals can learn from the study of whales. This came up while I was reading Watching Giants: The Secret Lives of Whales by Elin Kelsey. My original … Read more »
Darth Vader and the New York Stock Exchange
Is this going to improve the image of the stock market? Darth Vader ringing the opening bell at the NYSE?! Lucasfilm Ltd. Brings the Force to the New York Stock Exchange This Holiday Season – press release After more than 30 years, Star Wars maintains its position as the #1 selling licensed toy property in … Read more »
Out With the Old, In With the New
New Year’s Eve is generally a time to reflect on the past and look forward to the future. For many it also involves an excessive amount of alcohol, an expensive dinner in a crowded restaurant, or a long wait for Chinese food delivery. I’m sure there is a compliance story in there somewhere. But I’m … Read more »
Six Mistakes Executives Make in Risk Management
Nassim N. Taleb, Daniel G. Goldstein, and Mark W. Spitznagel discuss risk management and short comings in approaches in the October 2009 issue of the Harvard Business Review (subscription required). They offer up six mistakes in the way we think about risk: 1. We think we can manage risk by predicting extreme events. 2. We … Read more »
Perception, Dilbert and a Magical Management Necklace
Are your assumptions correct? You get a new tool to help manage your processes and everything starts working better. Is everything actually working better? Or is the data just being manipulated to look better? As is often the case, the pointy-haired boss can show us the problem. Often the compliance officer is like the pointy-haired … Read more »
In-House Counsel Sanctioned for Failing to Monitor the Preservation of Electronic Evidence
In the Swofford v. Eslinger case, the court sanctioned in-house counsel (but not outside counsel) for failure to preserve evidence. The attorney sanctioned was general counsel for a government entity, the Seminal County Sheriff’s Department. What was unique about this case was that the sanctions were brought against in-house counsel for spoliation of evidence even … Read more »
Merry Christmas
I’m taking a few days off for the holiday weekend. Image by Das Nili in Wikimedia: Christmas tree near the Quincy Market.jpg Read more »
The Twelve Days of Compliance
Sing it with me: On the first day of compliance, my audit gave to me: Madoff in a prison jumpsuit. . . On the second day of compliance, my audit gave to me: Two legal frauds, and Madoff in a prison jumpsuit. . On the third day of compliance, my audit gave to me: Three … Read more »
Social Networking is Serious Business
If you live in the Greater Boston area and have $45 lying around, I am speaking on social networking on January 15, 2010 hosted by the New England Chapter of AIIM. Social Networking is Serious Business Newton Marriott Hotel January 15, 2010 8:30 a.m. – 11 a.m. $40 AIIM NE members/$45 non-members I will be … Read more »