Doug Cornelius on compliance for private equity real estate
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 »
These are some of the compliance-related stories that recently caught my attention. Automation & Control Lessons in Latest SEC Enforcement by Matt Kelly in Radical Compliance We have an interesting enforcement action from the Securities and Exchange Commission this week, where the agency dinged a telecom company and its former executives $1.9 million for misleading … Read more »
In a startling announcement, the Department of Justice and the Securities and Exchange Commission filed charges against Congressman Christopher Collins from New York. There has long been controversy around lawmakers and their staff trading on information obtained during their government service. That resulted in the passage of the Stop Trading on Congressional Knowledge (STOCK) Act … Read more »
A new program from the Securities and Exchange Commission will always (hopefully) catch my attention. I paused for a minute when I saw a press release for the SEC’s update of PAUSE, the “List of Firms Using Inaccurate Information to Solicit Investors.” That sounded interesting. The list even had a catchy acronym. PAUSE stands for … Read more »