Finding A Way.

Mark Your Calendars for Your Annual Review

Before you even start reading this, go to Outlook or whatever calendar you use, pick a date, and put in “Annual Review.”  Any time in the year...

SEC Issues Risk Alert: Advisers’ Due Diligence Processes for Selecting Alternative Investments

Whether or not 2014 will be the year of the alternative investments, many predict that this asset class will play an increasing role in the portfolio allocation...

Year in Review: SEC Round Up for 2013

I love taking stock of the highlights of a year as it draws to a close, so I am doing a mini-series of posts on topic.  The...

SAC Capital, Insider Trading and the Southern District

It would be old news already if the case had not garnered so many superlatives.  One of the country’s most famous hedge fund managers.  The largest insider...

SEC Examinations Targeting Advisers Who Are Still Waiting for Godot

I have worked with a number of advisers who have never ever been examined by the SEC, not once in their 10 +, 15+, etc. years of...

Three Steps to an Effective Whistleblower Program

Everyone should have one. If you need more convincing, please read my post, or any post for that matter, about the record $14 million award the SEC...

FINRA’s Conflicts of Interest Report: Bridging the Great Divide?

FINRA issued a report on conflicts of interest within the broker-dealer industry last month.  It is the result of a review initiated in July 2012 at a...

Taking It To A New Level — SEC Awards Whistleblower Unprecedented $14 Million

The Securities and Exchange Commission awarded more than $14 million to a whistleblower earlier this month.  The information led to an enforcement action that recovered substantial investor...

What Are the Hallmarks of a Strong Compliance Program?

I thought it would be interesting to hear it from the horse’s mouth once more. Speaking before the Society of Corporate Compliance and Ethics’ 12th Annual Compliance...

SEC Brings First Action Under Chief Compliance Officer Rule

The SEC recently sanctioned a former portfolio manager  under Rule 38a-1(c) of the Investment Company Act, which prohibits misleading and obstructing a chief compliance officer (CCO).  Carl...