The Death of the Corporate Transparency Act? (or not)

If you’re reading this, you’ve probably put a bunch of time into getting ready for compliance with the Beneficial Ownership Information reporting under the Corporate Transparency Act. You already know that there has been a nationwide injunction put in place to temporarily stop implementation of the requirements. Texas Top Cop Shop, Inc. v. Garland (E.D. Tex. … Read more »

A Step Up in Fraud From the Nigerian Prince

In this case, the “prince” was a well established financial adviser. Chibuzo Augustine Onyeachonam, Stanley Chidubem Asiegbu, and Chukwuebuka Martin Nweke-Eze created websites using the the names of real US-based financial professional. For example assuming I was known financial professional and wanted to impersonate me they would create dougcornelius.com and send an email from doug … Read more »

SEC Compliance Outreach Seminar

On Thursday November 7, the Securities and Exchange Commission produced an online compliance outreach program for registered investment adviser and investment companies. Here are a few notes and points that caught my attention. There were lots of video production issues and sound issues throughout the program. It kicked off with a welcome from Chair Gensler, … Read more »

Before and After Reg BI

The case against PHX Financial caught my attention because it involves actions of the firm before and after the compliance date of Regulation BI. During the Pre-Reg BI Period, PHX failed reasonably to supervise Representative 1, within the meaning of Section 15(b)(4)(E) of the Exchange Act, with the view to preventing and detecting Representative 1’s … Read more »