Doug Cornelius on compliance for private equity real estate
These are some of the compliance-related stories that recently caught my attention or I missed while on vacation. SEC Ratifies Appointment of ALJs and Lifts Stay on Pending Administrative Proceedings The Securities and Exchange Commission (“SEC” or “Commission”) has issued an order clearing the way for cases to proceed before its own administrative law judges … Read more »
Yesterday, the Senate voted to confirm the nomination of Elad L. Roisman to be a member of the Securities and Exchange Commission. Mr. Roisman fills the vacant seat left by Michael Piwowar. This is the fourth Commissioner appointed by President Trump. I expect we will see pictures of the swearing in ceremony this morning. Mr. … Read more »
Getting a free meal is one of the few perks of staying late at the office for many financial services firms. The firm is willing to pay some set amount if the employee stays after some deadline. Most figure that the person is going to be more productive if he or she is not starving. … Read more »
Since it’s back-to-school day for my community, I thought I would go back to the basics. The SEC’s Office of Investor Education and Advocacy 2014 Investor Alert identifies potentially fraudulent unregistered offerings with features that indicate a problem. The alert goes through 10 red flags for you to note about private placements. Private placements are not … Read more »
If you are running a Ponzi scheme, don’t send a video to your investors that you are running a Ponzi scheme. According to the Securities and Exchange Commission Complaint, EquityBuild was selling notes secured by real estate by promising safety and high returns. (Hopefully, you realize those things don’t go together.) In reality, EquityBuild was … Read more »
Merrill Lynch has lots of relationships and is trying to manage an advisory business, a brokerage business and an investment banking business. It got into trouble for letting the last two interfere with the normal operations of its advisory business. In general during the time of the SEC action, a material change in any product … Read more »
According to a tweet from President Trump, he asked the Securities and Exchange Commission to study the possibility of moving from quarterly to semi-annual reporting for public companies. In speaking with some of the world’s top business leaders I asked what it is that would make business (jobs) even better in the U.S. “Stop quarterly … Read more »
Can I outsmart the economist Steven Landsburg? I tried getting the answers right in his new book: Can You Outsmart an Economist? The answer: No. I can’t. Mr Landsburg’s book present us with 100+ puzzles to illustrate some principles of economics. The puzzles bleed into understanding the interpretation of those principles in statistics, law, math, science … Read more »
These are some of the compliance-related stories that caught my eye recently. Compliance Activists vs. Effective Compliance Professionals by Roy Snell Some of the most ineffective compliance professionals I have met run up and down the hall with their hair on fire over every little thing. Ineffective compliance professionals see their role as that of … Read more »
I read about a new red flag in the Securities and Exchange Commission’s exam process for investment advisers. Examiners are looking for Chief Compliance Officers with web-based email addresses. So, if your CCO uses a gmail, or yahoo.com email address on your Form ADV filing, the SEC will treat that as a red flag. This … Read more »