Doug Cornelius on compliance for private equity real estate
I was looking through an issue under Rule 206(4)-5. The Securities and Exchange Commission limits the ability of investment advisers and fund managers to contribute to certain politicians that can influence investment decisions for state pension funds. Under Rule 206(4)-5, you can contribute up to $150 to any candidate or up to $350 if you can vote … Read more »
California’s soon to be enacted new law, AB 2833, requires every California public investment fund to require its alternative investment vehicle fund managers to make disclosures regarding fees and expenses. AB 2833 mandates that that every California public investment fund (that includes CalSTRS and CalPERS) must make the following disclosures at least annually: The fees and … Read more »
These are some of the compliance-related stories that recently caught my attention. Whistle-Blowing Insiders: ‘Game Changer’ for the S.E.C. by Peter Henning in DealB%k Since the program’s creation in 2011, the S.E.C. has received more than 14,000 tips, including almost 4,000 last year. That number falls well short of the original estimate of 30,000 submissions each … Read more »
I have a written a few stories on the SEC’s case against Louis Schooler and his firm, Western Financial Planning Corp. The Securities and Exchange Commission brought charges against them for a real estate investment scheme. Schooler was selling general partnership interests that owned real estate using what looked like inflated valuations. By default general … Read more »
With big data, comes formulas to parse through the data trying to make sense of it. Those algorithms can help make sense of the data and help filter through the noise to find trends. But those algorithms can also be easily misused and have harmful, if unintended consequences. Cathy O’Neil explores these problems in Weapons of … Read more »
These are some of the compliance-related stories that recently caught my attention. Maybe you need something to read over Labor Day Weekend? Conflicted Feelings About Conflict Minerals by Matt Kelly in Radical Compliance Don’t die of shock, but a new government report finds that compliance with the Conflict Minerals Rule is still sputtering. That’s the … Read more »
Continuing with my look at the changes to Form ADV, I spent some time looking at the new umbrella registration. One investment adviser (“Filing Adviser”) will be able to file a single Form ADV on behalf of itself and other investment advisers (“Relying Advisers”). This tackles the problem fund managers had when the manager was … Read more »
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 »