Doug Cornelius on compliance for private equity real estate
Continuing this week on the changes to the Form ADV is a revision to Item 1.J that lists the chief compliance officer. The new Form ADV will require a registered investment adviser to disclose whether the firm’s CCO is compensated or employed by someone other than the adviser. That is, the SEC wants to know … Read more »
The biggest change to the Form ADV is reporting on separately managed accounts. The Securities and Exchange Commission is looking for data and insight into advisers’ operations. I think the benefit to consumers is a side benefit. I have to admit that I was confused as I was browsing through the new changes to Form … Read more »
The Securities Exchange Commission published an update to Form ADV last week. I’m going to devote this week’s stories to some of the new requirements. Today, I’m looking at reporting of social media. Item 1.I of Part 1A of Form ADV currently requires registered investment advisers to list their websites. The SEC is casting a wider … Read more »
These are some of the compliance-related stories that recently caught my attention. Private Fund Advisers Must Pay Close Attention to Nuances under Pay-to-Play Restrictions in Light of Upcoming Elections Nationwide As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political … Read more »
If you are going to originate some shady mortgages, maybe you shouldn’t nickname the program the “hustle.” If you package up the mortgages and sell them as good mortgages, it would seem you are committing fraud. But maybe not. It may come as no surprise that the company running the “hustle” was Countrywide. According to … Read more »
Apollo has been variously recognized as a god of sun, truth, healing, and poetry, and more in classical Greek and Roman mythology. It’s namesake private equity firm has settled charges with the Securities and Exchange Commission that it was less than truthful in disclosing fees charged to investors. The main thrust of the Apollo case … Read more »
It only takes a few minutes of watching the national news before you will see a crime story with police dressed in battle gear. In Rise of the Warrior Cop, Radley Balko traces the history of US law enforcement to see how we got to this. Mr. Balko thinks the founding fathers, distrustful of a standing … Read more »
These are some of the compliance-related stories that recently caught my attention. Anti-Corruption Laws and Other International Risks – What it Means for the Real Estate Industry and How to Protect against Risks by Ropes & Gray The real estate industry is commonly viewed to be higher risk in light of the numerous government touch … Read more »
I tripped across an enforcement case that was so full of wrong things that I had to re-read it. In one sense, I saw a clever way to exploit an investment feature. On the other hand, the whole investment felt morally wrong, was deceptive and violated at least one important rule under the Investment Advisers … Read more »
Pharmaceutical company stock is known to be volatile depending on success or failure of drug trials. As pharma companies become successful they become targets for larger pharma companies looking to supplement their lines. The Securities and Exchange Commission filed two actions recently for suspect trading in pharma companies. The first case is a bread and … Read more »