I’m attending the PERE CFOs & CCOs Forum. These are my notes from the session. Operations are increasingly the difference maker in an environment of declining revenue per AUM. If we are going to be a cost center, we should be the best. International operations takes up a disproportionate amount of time. Investing overseas has … Read more »

I’m Asking For Your Money
Compliance Building is a free resource I publish for me, and share with you, to help the compliance profession. But I’m asking for money. I should point out that the money is not for me; It’s for charity. I’m riding the Pan Mass Challenge in 2016 and hope you will consider supporting me this year. … Read more »
Dodd-Frankly, My Dear, I Don’t Give..
Perhaps one day there’ll be another famous movie line: “Dodd-Frankly, my dear, I don’t give…” But probably not. Its not clear if Dodd-Frank has been a success or a failure. It certainly has been a change. From the regulated side, I think the failure or success depends on which part of Dodd-Frank affects you. New … Read more »
Compliance Bricks and Mortar for May 13
These are some of the compliance-related stories that recently caught my attention. Stop Faxing by David Smyth in Cady Bar the Door The problem was the same as with all faxes: nobody wants them. They want emails instead. So when the firm set up an electronic faxing service, they added an extra step in the … Read more »
Does Compliance Work?
This has been an existential question for a long time. How do you measure compliance success? How do you know if it’s working? Sean Griffith, director of the Corporate Law Center at Fordham University in New York casts a skeptical eye on compliance through the lens of corporate governance in a new law review article: Corporate … Read more »
Alternative Funds and Valuations
It should come to no surprise that alternative funds have an extra level of scrutiny when it comes to valuations. RD Legal Capital is under scrutiny by the Securities and Exchange Commission according to a story in the Wall Street Journal. RD Legal is in litigation finance with a strategy to to buy stakes in … Read more »
Political Contributions Rule Continues to Be Painful
With the contenders for President nearly locked up for the conventions, I’m stuck worrying about political contributions. At least one fund manager continues to look for an exemption after a small oversight. The firm hired a new senior investment professional in September 2014. A year earlier, the employee had made a contribution to Bruce Rauner … Read more »

Compliance Bricks and Mortar for May 6
These are some of the compliance-related stories that recently caught my attention. We Are All Victims… Except Richard Bistrong by Roy Snell in The Compliance & Ethics Blog Richard was a successful international salesman who selected a bad principle… bribery. He stuck to that principle like glue for 10 years. Before he got caught he … Read more »

Private Equity Real Estate Top 50 – 2016 Edition of Who is Registered
Private Equity Real Estate has released its ranking of the top 50 real estate private equity fund managers. As I have done in the past, I parsed the list to see which managers are registered with the Securities and Exchange Commission as investment advisers. Rank Firm Headquarters Registration 1 The Blackstone Group New York Registered … Read more »
Custody Failure Pinned On the Gatekeepers
I remember the SFX case because the CCO was charged for compliance failures. Now the auditors of SFX have been been charged for their failures. SFX Financial Advisory Management Enterprises is wholly-owned by Live Nation Entertainment and specializes in providing advisory and financial management services to current and former professional athletes. The SEC charged SFX’s … Read more »