The Trump Administration’s attack on regulations just made a sweep through the financial industry. The Securities and Exchange Commission, The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency all clarified that staff guidance is not a regulation. SEC Chairman … Read more »
Compliance Bricks and Mortar – Florence Edition
To all of you in the path of Hurricane Florence, I wish you the best in your battle against the winds and rain. If you need something to read, these are some of the compliance-related stories that recently caught my attention Why Compliance Programs Fail—and How to Fix Them by Hui Chen and Eugene Soltes … Read more »
Yes, A Cryptocurrency Can Be a Security
Earlier this week, a federal judge denied a claim that a cryptocurrency is not a security under the federal securities law. The judge didn’t say that it was a security. Instead, he ruled that a reasonable jury could conclude that the cryptocurrency is a security. This ruling comes from the SEC enforcement action against RECoin, … Read more »
Browns Don’t Lose, But a Player Does
For the first time in 13 years, the Cleveland Brown did not lose on their NFL opening weekend. Being the Browns, they didn’t win either. They had to compete without the help of Mychal Kendricks. The now former linebacker was cut by the Browns after charges of insider trading. The $1.2 million in insider trading … Read more »
Help the Other Fellow
On this day with memories that come from an act of hatred, please find an opportunity to commit an act of kindness. Help the other fellow. Read more »
Real Estate Broker Guilty of FCPA Violations
I’m not sure how I missed the sad tale of Joohyun Bahn before now. He agreed to an SEC order last week for FCPA violations. This was in connection with his criminal sentencing that also happened last week, after first being arrested in January 2017. It’s uncommon for real estate to insect with the FCPA, … Read more »
Compliance Bricks and Mortar for September 7
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 »
First Full Day of a Full Strength SEC
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 »
Broken Windows at Wells Fargo
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 »
10 Red Flags that an Unregistered Offering May Be a Scam
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 »