Compliance Building Doug Cornelius on compliance for private equity real estate

Time 2021-01-10 13:04:56

Web Name: Compliance Building Doug Cornelius on compliance for private equity real estate

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Compliance Building Doug Cornelius on compliance for private equity real estate Goodbye Office of Compliance Inspections and Examinations. Hello Division of Examination. The Securities and Exchange Commission decided that OCIE, with 23% of the SEC employees, is probably more than an office and elevated it to the level of Division by naming it the Division of of Examinations. That puts it on equal name status with Read more I m not sure what Anti-Money Laundering has to do with the United States military, but Congress included big changes to anti-money laundering law in the National Defense Authorization Act for 2021. After a veto by President Trump and an override by Congress, NDAA has become the law, including Section 6401-6403, the Corporate Transparency Act. It s Read more Back in 2017, the Supreme Court inKokesh v. Securities and Exchange Commissionpointed out that the disgorgement claims made by the Securities and Exchange Commission are penalties and therefore subject to the five-year statute of limitations. The Kokesh decision left some question about whether the SEC could pursue disgorgement at all. The Supreme Court did not Read more The Secretary of the Commonwealth filed its first enforcement action under the Massachusetts Fiduciary Rule. Robinhood and its gamification of investing are in its bullseye. The Massachusetts Securities Division adopted amendments to 950Mass. CodeRegs.12.200 earlier this year as they relate to the standard of conduct applicable to broker-dealers and agents. The amendments apply a fiduciary Read more From xkcd: https://xkcd.com/2398/ Meanwhile on Wednesday, the Securities and Exchange Commission is scheduled to vote on a new advertising rule for registered investment advisers. From the Sunshine Act notice for the meeting; 2. The Commission will consider whether to adopt amendments under the Investment Advisers Act of 1940 to update rules that govern investment adviser Read more BlueCrest Capital was wildly successful as a hedge fund for many years. Its principals were wealthy enough that they could start a new fund with their own money and dedicate traders to running that new proprietary fund. That s okay, even if the trading strategies between the new proprietary fund the existing hedge fund overlap. Compliance Read more The SEC s Office of Compliance Inspections and Examination launched a lot info last week. It livestreamed a National Investment Adviser/Investment Company Compliance Outreach and published a Risk Alert on notable compliance issues identified by OCIE related to Rule 206(4)-7. Peter Driscoll, Director of OCIE, started off the program highlighting three words that should be applicable Read more The Securities and Exchange Commission announced a new initiative focused on complex products: The Exchange-Traded Products Initiative. It s led by the Division of Enforcement s Complex Financial Instruments Unit. It was developed by Armita Cohen and data analytics specialists Daniel Koster and Jonathan Vogan and has been coordinated by Ms. Cohen. The first inkling of this initiative Read more The SEC s Office of Compliance Inspections and Examinations ran a sweep it called the Multi-Branch Initiative. It published a risk alert on November 9 with its findings. The Risk Alert is mostly a collection of typical compliance problems: Custody of client assets Fees and expenses Oversight and supervision of supervised persons Advertising Code of ethics Read more Advisers to private funds, usually rely on the audited financial statement method to satisfy the Custody Rule. The Chief Accountant’s Office of the Division of Investment Managementreleased a Dear CFO Letter last week that raises issues about using combined financial statements to satisfy the custody rule. You may have missed this possibly important compliance change Read more

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