Doug Cornelius on compliance for private equity real estate
Robinhood experienced massive growth during the pandemic. It had had 5.1 million cumulative net funded accounts by the end of 2019, 12.5 million cumulative net funded accounts by the end of 2020, and 22.7 million cumulative net funded accounts by the end of 2021. Based on the Securities and Exchange Commission’s action against Robinhood, the … Read more »
SpeedRoute is a registered broker-dealer that specializes in routing U.S. equities orders for broker-dealer clients to trading platforms for execution. Being a registered broker-dealer means that SpeedRoute has to comply with the Bank Secrecy Act. Among many other things, that requires SpeedRoute to file Suspicious Activity Reports for suspicious transactions that it knew, suspected, or … Read more »
The Bank Secrecy Act requires broker-dealers to file suspicious activity reports. Under the SAR Rule (31 C.F.R. § 1023.320(a)(2)), every broker-dealer has to file a report for a transaction of at $5000 that That’s all a bit vague. So FINRA has produced a list of more actionable items, most recently compiled in FINRA Regulatory Notice … Read more »
Over the years, the Financial Crimes Enforcement Network (FinCEN) has required banks, brokers, and other financial entities to officially report suspicious activities of its customers. Investment advisers and private fund managers have managed to sty outside the requirements. In large part, that’s because a fund’s custodial accounts are already subject to the self-policing. since the … Read more »
The Financial Crimes Enforcement Network released its full year 2011 update (.pdf) of mortgage loan fraud reported suspicious activity reports. It reveals a 31% increase in submission.It also shows some of the trends that lead to the 2008 financial crisis. Financial institutions submitted 92,028 MLF SARs in 2011, compared to 70,472 submitted in 2010. Financial … Read more »