Frost Management Company was what seems like a typical venture capital fund complex that had raised five private funds and invested the capital in a portfolio of start-up companies.  The SEC says it found undisclosed affiliate payments and brought a suit against Frost. Frost was an “exempt reporting adviser” with a filing from 2017. It apparently failed to file to renew the filing. Before jumping into the charges, the first item to note…

Regulatory actions against compliance officers catch my attention. I don’t think compliance should be the target unless compliance engaged in the wrongdoing. I saw the action against Joseph Storms,m identified as a “compliance associate” and dove in. Mr. Storms entered the securities industry as a compliance intern in 2005 with FINRA member firm Raymond James & Associates, Inc. I’m not sure what happened during the next ten years, but he is identified as being a…

Regulatory actions against compliance officers catch my attention. I don’t think compliance should be the target unless compliance engaged in the wrongdoing. I saw the action against Joseph Storms,m identified as a “compliance associate” and dove in. Mr. Storms entered the securities industry as a compliance intern in 2005 with FINRA member firm Raymond James & Associates, Inc. I’m not sure what happened during the next ten years, but he is identified as being a…

These are some of the compliance-related stories that recently caught my attention. Board Members Should Take Note — Delaware Supreme Court Issues Important Decision on Caremark Compliance Standardby Michael VolkovCorruption, Crime & Compliance The Delaware Supreme Court returned to this issue in a recent case – Marchand v. Barnhill et al, HERE, a case involving Blue Bell Creameries  and a listeria outbreak.  The facts, while compelling, involve a serious health and safety issue but…

The SEC charged Commonwealth Equity Services, LLC (d/b/a Commonwealth Financial Network), a registered investment adviser and broker-dealer, with failing to disclose material conflicts of interest related to revenue sharing Commonwealth received for certain client investments. According to the SEC’s complaint, Commonwealth had a revenue sharing agreement with its clearing broker for trades in their accounts. Under the agreement, Commonwealth received a portion of the money that certain mutual fund companies paid to the clearing…

If you’re reading this on Friday morning, I’ll be on my bike riding from New York border to Sturbridge for the unofficial Day Zero ride of the Pan Mass Challenge. The official start is Saturday morning, when I’ll ride from Sturbridge to Bourne, and then from Bourne to Provincetown on Sunday. That will be almost 300 miles of bike riding, surrounded by thousands of other riders raising money to fight cancer. Thanks to so many…

If you’re reading this on Friday morning, I’ll be on my bike riding from New York border to Sturbridge for the unofficial Day Zero ride of the Pan Mass Challenge. The official start is Saturday morning, when I’ll ride from Sturbridge to Bourne, and then from Bourne to Provincetown on Sunday. That will be almost 300 miles of bike riding, surrounded by thousands of other riders raising money to fight cancer. Thanks to so many…