Doug Cornelius on compliance for private equity real estate
The U.S. Securities and Exchange Commission proposed to increase the net worth threshold for “Qualified Clients” from $2 million to $2.1 million. Rule 205-3 currently requires “qualified clients” to have at least $1 million of assets under management with the adviser or a net worth of at least $2 million. Under the Investment Advisers Act, an … Read more »
The recent insider trading case against William “Billy” Walters of Las Vegas is fascinating for all of the players involved, including him. Plenty has been written about the charges because it implicates pro golfer Phil Mickelson and former Dean Foods board member Thomas C. Davis. All three are implicated in insider trading. How did they get … Read more »
In We The People, Juan Williams tackles the history of the 20th century through the lens of some keys figures and tries to pin those societal changes back to the original thoughts of the founding fathers. At first glance, it looks like Mr. Williams might use the ‘great man theory‘ of history. The people he picks are … Read more »
These are some of the compliance-related stories that recently caught my attention. Compliance Goes to School by Geoffrey Parsons Miller In my view there is no one “right” answer to the question of where compliance fits in a law school’s curriculum, just as there is no “one-size-fits-all” compliance program. A good model, however, is that … Read more »
I’m attending the PERE CFOs & CCOs Forum. These are my notes from the session. On a scale of 1 to 5 the attendees created a classic bell curve on how confident we felt about our cybersecurity programs, with most choosing “3.” The panel labeled social engineering as the upcoming threat. There were several stories … Read more »
I’m attending the PERE CFOs & CCOs Forum. These are my notes from the session. Bruce Karpati interviewed Igor Rozenblit, Co-head of the Private Fund Unit at OCIE, Securities and Exchange Commission. Of course, Igor’s views are his own and do not necessarily reflect the views of the SEC or the Commissioners. Prior, when Bruce … Read more »
I’m attending the PERE CFOs & CCOs Forum. These are my notes from the session. Most of the attendees are using private placement to get into Europe, with the rest split between a parallel Europe fund and reverse solicitation. AIFMD arrangements are possible with a third-party who has the AIFMD passport. The non-EU firm acts … Read more »
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 »
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 »
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 »