The Trump Organization’s Compliance Program Begins

Last week, the Trump Organization kicked off its compliance program by making two appointments. Bobby Burchfield will be independent ethics adviser. He’ll be responsible for signing off on transactions that could raise ethics or conflicts of interest concerns. George Sorial will become chief compliance counsel. In the January 11 press conference, Sheri Dillon announced: [T]o … Read more »

Compliance Bricks and Mortar for January 27

These are some of the compliance related stories that recently caught my attention. Trump Gets Subtle Pre-taliation Warning by Matt Kelly in Radical Compliance On Wednesday the Office of Special Counsel issued a reminder that any policies about communications from government employees—like, say, telling them to stop talking about climate change; or to stop talking entirely—must … Read more »

CCO Liability for False Statements on Form ADV

Susan Diamond was Chief Compliance Officer of Saddle River Advisors. Now, Ms. Diamond is out of pocket for a $15,000 penalty and is subject to a nine-month suspension from being associated with any investment adviser or other financial services firms. After the suspension, she will be prohibited from acting in the securities industry in certain managerial … Read more »

Red Hot SEC Exam Topics

IA Watch presented a webinar: Red Hot SEC Exams Topics in 2017, Plus Exam-Prep Steps from Peers Who’ve Survived Recent Exams. The presenters were Fred Shaw, Principal/Director of Compliance, Hamilton Lane Adam Reback, CCO, J. Goldman & Co Chuck Daly, Principal, Constellation Advisers Michelle Martin, CCO, Longfellow Investment Management These are my notes: Even though there … Read more »

Compliance Bricks and Mortar for January 20

These are some of the compliance related stories that recently caught my attention. Experts Ponder Role of Trump Organization Compliance Counsel by SAMUEL RUBENFELD in WSJ.com’s Risk & Compliance Journal As compliance counsel, the person’s ethical obligation will be to the organization, not to the president, making the role less robust than retaining an independent … Read more »

The SEC Really Means It About Pretaliation Severance Agreements

In case you were not clear that the Securities and Exchange Commission is serious about enforcing Rule 21F-17, BlackRock is the latest to run the perp walk. The SEC accused the money management giant of improperly using separation agreements that forced employees to waive their ability to obtain whistleblower awards. The SEC adopted Rule 21F-17, which provides in … Read more »