Doug Cornelius on compliance for private equity real estate
According to the SEC Complaint and Criminal Complaint, Dawn Bennett lived the life a classic ponzi schemer who got in over her head and continued to lie and cheat, perhaps hoping to find a way out. The story caught my attention for two reasons. The first was the implication that Ms. Bennett used a voodoo … Read more »
These are some of the compliance-related stories that recently caught my attention. In Defense of Compliance Checklists by Michael Volkov in Corruption, Crime & Compliance If a compliance officer can persuade the business side to take responsibility for compliance, compliance officers should develop simple checklists and other mechanisms to support the business. For example, the … Read more »
The United States has a long arm in imposing financial restrictions. U.S. companies cannot assist their foreign subsidiaries or affiliates with sales to sanctioned countries or persons on the blocked persons list. A US company got caught doing this. White Birch was accused of facilitating the sale and shipment of Canadian paper from White Birch’s … Read more »
One of the arguments made by Lynn Tilton in her battle against the administrative law judges of the Securities and Exchange Commission was the inherent unfairness of that judicial system compared to the federal courts. She failed in her battle against the system, but won on the merits. From October 2010 through May 2015, 90 … Read more »
George Saunders’s first novel is a weird, wonderful and woeful book about young Willie Lincoln, son of the President, who is trapped in the “bardo.” That is a Tibetan term for the intermediate state or gap we experience between death and our next rebirth. Willie has died and been taken to Oak Hill cemetery, buried in a … Read more »
These are some of the compliance-related stories that recently caught my attention. The Effectiveness of SEC Enforcement in Deterring Financial Misconduct by Shiu-Yik Au This paper examines how the Securities and Exchange Commission’s (SEC) enforcement actions and whom they target deter future financial misconduct. An enforcement action reduces the incidence of misconduct in other firms … Read more »
Rusty Tweed may have been trying to make good investments for his clients. He knew a guy that had a new quantitative trading strategy for blue chip stocks. Rusty raised money form his clients to invest with the quant manager. Problems started right at the beginning, according the complaints filed by FINRA and the Securities … Read more »
The First Every Cryptocurrency Back By Real Estate, REcoin, is a big scam. At least according to the Securities and Exchange Commission. Several weeks ago the SEC posted an Investor Bulletin in Initial Coin Offerings. In the bulletin, the SEC raised the issue that an initial coin offering could easily be considered an offering of … Read more »
Lynn Tilton and her firm, Patriarch Partners, are known for their high-risk, high-return investments in distressed companies. The Securities and Exchange Commission brought a case against her and the firm claiming that they were using improper valuations, failing to mark down assets when the investment became more distressed. Ms. Tilton chose to fight the charges … Read more »
There is no place for hyperbole or fudging numbers in disclosure of investment returns. The Boston office of the Securities and Exchange Commission made that point with Aegerion Pharmaceuticals in its enforcement case. According to the SEC complaint, Aegerion’s CEO said that the “vast majority of patients” who were given prescriptions for one of its drugs were … Read more »