Doug Cornelius

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These are some of the compliance-related stories that recently caught my attention. Listing Gaps, Merger Waves, and the Privatization of U.S. Equity Finance by Gabriele Lattanzio, William L. Megginson and Ali Sanati in The CLS Blue Sky Blog The number of U.S. listed companies declined by almost half between 1996 and 2012, from 8,090 to 4,102, and had risen only slightly, to 4,336, by year-end 2017. However, the real market valuation of these listed companies tripled…
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Enforcement actions by financial regulators can cause compliance professionals to rethink their career choice. In the majority of cases the SEC brings against CCOs, (1) the compliance officers are involved in misconduct that is unrelated to their compliance function or (2) the CCOs have engaged in efforts to obstruct or mislead the investigation. Typically in these cases, the targeted compliance officers wore more than one hat. But not always. Take a look at the Southwind …
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These are some of the compliance-related stories that recently caught my attention, The Fall of the Alamo: Analogy for Compliance Officers by Tom Fox in FCPA Compliance & Ethics [March 6] is the anniversary of the most historic day of many in the history of the great state of Texas, the date of the fall of the Alamo. While March 2, Texas Independence Day, when Texas declared its independence from Mexico and April 21, San…
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These are some of the compliance-related stories that recently caught my attention. CCOs Facing Retaliation by Matt Kelly in Radical Compliance So how should a compliance or audit professional handle retaliation? When should you take your concerns to regulators, or contemplate a lawsuit against your employer? To explore those questions I spoke with Jason Zuckerman, a lawyer in Washington who represents whistleblowers in retaliation cases. You can hear the full podcast at the top of…
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The SEC cancelled the adviser registration of an internet investment adviser because it never launched its website.   Kevin Ajenifuja registered his firms with the SEC by filing its Form ADV on May 28, 2015. He stated the eligibility for registration was because the firm was an “Internet Investment Adviser.” Internet investment advisers typically are not eligible to register with the SEC. They do not manage the assets of their clients and therefore do not meet…
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The Custody Rule is full of foot-faults. The concept is easy: have a third party make sure that the investment adviser is not stealing money. That turns out to be a bit harder in execution. Mohlman Asset Management Fund was using the accounting firm Katz, Sapper & Miller, LLP to help with its funds’ financial statements. Mohlman asked the firm to also audit the funds. A fund manager can satisfy the Custody Rule requirements if…
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Apparently, the blockchain makes everything cooler as a way to invest. Even securities laws shouldn’t get in the way. Reginald Buddy Ringgold, III thought he had escaped from the grasp of the SEC when a court refued to issue a preliminary injunction against his Blockvest ICO. The court changed its mind and slapped an injunction in place. Back in October, the SEC brought charges against Mr. Ringgold, alleging that that they were planning…
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Apparently, the blockchain makes everything cooler as a way to invest. Even securities laws shouldn’t get in the way. Reginald Buddy Ringgold, III thought he had escaped from the grasp of the SEC when a court refued to issue a preliminary injunction against his Blockvest ICO. The court changed its mind and slapped an injunction in place. Back in October, the SEC brought charges against Mr. Ringgold, alleging that that they were planning…
There were massive problems at the schools in Atlanta. Funding problems choked schools from needed capital investments and programming dollars. There was pressure to perform well on standardized tests under the No Child Left Behind Law, with fewer resources. That pressure was too much for some principals and school teachers. They cheated and changed answers on their students tests. Shanti Robinson is one of the teachers who went to trial for cheating on the standardized…
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The Institutional Limited Partners Association and 35 of its member institutions sent a letter to the Securities and Exchange Commission pushing for stronger regulations on private equity advisory firms.   ILPA is asking the SEC to make 7 changes. Rescind the Heitman Capital Management No-Action Letter, issued in 2007. SEC enforcement settlements with private fund advisers should not be conditional on them not seeking indemnification from their investors. Require private fund advisers to explicitly and…