Executive Compensation, Where Everyone is Above Average

It seems like executive compensation consultants come from Lake Wobegon, where “all the women are strong, all the men are good looking, and all the children are above average.” I think executives should be compensated for out-performing their peers. They shouldn’t be punished for a negative performance due to external forces if they still out-performed … Read more »

New Compliance and Disclosure Intepretations for Regulation FD

As part of the Updates to Compliance and Disclosure Interpretations, the SEC has published new compliance and disclosure intepretations for Regulation FD. I found these CD&I’s particularly interesting in light of the SEC’s loss in the Cuban case. The SEC seems to be providing a better roadmap for disclosure of information. Here are a few … Read more »

Updates to Compliance and Disclosure Interpretations

The staff of the Securities and Exchange Commission’s Division of Corporation Finance has updated a bunch of Compliance and Disclosure Interpretations. Here are a few questions that caught my eye, with a snapshot of the answer. Follow the question’s link for the complete answer. There are many more new and revised questions under the Securities … Read more »

AIMA Warns of Global Impact of EU AIFM Directive

The Alternative Investment Management Association has warned that the European Commission’s draft directive on Alternative Investment Fund Managers would negatively affect fund managers and investors around the world if enacted into European law. The Directive applies primarily to any Alternative Investment Fund Managers which is established in an EU Member State and which provides management … Read more »

Control Components Inc. and the FCPA

Control Components Inc. pleaded guilty to violating the anti-bribery provisions of the Foreign Corrupt Practices Act and the Travel Act, admitting to bribing foreign officials in a decade-long scheme. As part of the plea agreement, Control Components agreed to pay a criminal fine of $18.2 million; create, implement and maintain a comprehensive anti-bribery compliance program; … Read more »