Doug Cornelius on compliance for private equity real estate
With BitCoin breaking through the $10,000 barrier and growing interest in the uses of the underlying blockchain technology, everyone is looking to cash in using virtual currency. As with an IPO, the goal of investors in an Initial Coin Offering is get in early and cheap before the market takes the price up. The Securities … Read more »
The Consumer Financial Protection Bureau has been a political hotspot since it was first proposed in the wake of the 2008 financial crisis. The Republican leadership miscalculated in blocking Elizabeth Warren from becoming the first CFPB Director, which allowed her to turn to election as Senator and becoming a much larger political figure. Her replacement … Read more »
Instead of shopping (or working), I’m off on a bike ride. If you are looking for something compliance-related to read, here are few stories that recently caught my attention. Stock Trades of SEC Employees by Shivaram Rajgopal (Columbia Business School) and Roger M. White (Arizona State University) In March 2009, H. David Kotz, then Inspector … Read more »
I’m suffering from holiday creep and checking out the blog ahead of the actual holiday. Be compliant over the long weekend. Read more »
These are some of the compliance-related stories that recently caught my attention. Closing the Door on “Broken Windows” – What Does It Mean for Private Fund Sponsors? by David Wohl So do these new priorities, combined with the announced reduction of SEC enforcement staff by as much as 7%, herald a more “hands off” approach … Read more »
The Securities and Exchange Commission’s Enforcement Division just issued a report highlighting its priorities for the coming year a look back at enforcement actions that took place during the past year. The Enforcement Division’s Co-Directors Stephanie Avakian and Steven Peikin stated stated five core principles that will guide their enforcement decision-making: focus on the Main Street investor; … Read more »
With all of the SEC enforcement actions, it takes something related to my area or a quirk to catch my attention. The fraud that caught my attention this morning was a hedge fund manager claiming he no longer needed income and instead wanted to help friends and charitable causes. He told investors that his 20% … Read more »
According to a story by Jean Eaglesham in the Wall Street Journal, at least two employees working for SEC’s Inspector General have filed complaints alleging that he and his senior staff retaliated against them for calling out misconduct within the inspector general’s office. The allegations center on potential time and attendance fraud by a supervisor … Read more »
These are some of the compliance-related stories in my reading list. Your General Counsel is Your CECO? Really? by Joseph E. Murphy There continues to be controversy about whether a company’s general counsel should also be the CECO, especially at large companies. Putting aside the question of whether this is a good idea, however, I … Read more »
Dodd-Frank created a new legal definition for a “private fund” as pooled investment vehicles that are excluded from the definition of “investment company” under the Investment Company Act of 1940 by section 3(c)(1) or 3(c)(7) of that Act. Under 3(c)(1), the main limitations are that you have one hundred or fewer holders of beneficial interest … Read more »