Doug Cornelius on compliance for private equity real estate
We consider a challenge to the Final Rule by petitioners National Association of Private Fund Managers, Alternative Investment Management Association, Ltd., American Investment Council, Loan Syndications and Trading Association, Managed Funds Association, and the National Venture Capital Association collectively “Private Fund Managers”). For the following reasons, we VACATE the Final Rule. The central focus is … Read more »
“The Securities and Exchange Commission today announced that it will close its Salt Lake Regional Office (SLRO) later this year, reducing its regional footprint from 11 regional offices to 10.” The SEC’s Salt Lake City office has always stood out for covering such a small area. According to the press release, it has been the … Read more »
We’ve seen a few cases of trading on material, non-public information sprouting from spouses working at home. We just got another one, with a twist. Most recently, we had the case of a BP manager having her spouse spy on the merger activity she was working on for her company. That husband is tied up … Read more »
Film production is risky. There is need for capital to make the films and there are investors who want to say they helped fund a film. Christopher Conover had clients and investors who wanted to make those investments. Mr. Conover disclosed that he “receives fees related to Mr. Conover’s role as an Executive Producer for … Read more »
These are some of the compliance-related stories that caught my attention this week. The Board Member’s Oversight of AI Risk – Moving from Middle to Modern English By Sean Dowd, Rich Kando, and Chris Crovatto, AlixPartners LLPHarvard Law School Forum on Corporate Governance Risk assessments take on many forms, but there are three critical components … Read more »
The Securities and Exchange Commission published its 2024 report on Form ADV data for investment advisers. The number of advisers and total assets have increased dramatically. From 2012 when Dodd-Frank implemented a change requiring fund managers to register the number of registered investment advisers and Exempt Reporting advisers has increased by 60% from 13,222 to … Read more »
The Securities and Exchange Commission and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to have customer identification programs (CIPs). The proposed rule is designed to prevent illicit finance activity involving the customers of investment advisers. The … Read more »
These are some compliance-related stories that recently caught my attention. SEC Grants $2.4 Million Whistleblower Award to Compliance Official by Geoff SchwellerWhistleblower Network News The SEC order further clarifies that while the whistleblower learned of the misconduct in a role where their principal duties involve compliance or internal audit responsibilities, they were eligible for an … Read more »
You’re sitting poolside sipping on margaritas with your buddy. You’ve always wanted to work together and your buddy says that now would be a good time to do so. You ask, what about your current position. Your buddy, with a few margaritas in his gut, tells you that his current position is uncertain because the … Read more »
With the issuance of the Marketing Rule for Investment Advisers (Rule 206(4)-1) decades of interpretations and guidance were wiped out. We’ve been waiting to see what falls under those seven general prohibitions in the Marketing Rule. We’ve been thirsting for more guidance. We’ve gotten some additional clarification on the performance aspects of marketing. We know … Read more »