We’ve seen a few cases of trading on material, non-public information sprouting from spouses working at home. We just got another one, with a twist.
Most recently, we had the case of a BP manager having her spouse spy on
Doug Cornelius Blogs
Latest from Doug Cornelius
The One with the Bad Films
Film production is risky. There is need for capital to make the films and there are investors who want to say they helped fund a film. Christopher Conover had clients and investors who wanted to make those investments.
Mr. Conover
Investment Adviser Statistics
The Securities and Exchange Commission published its 2024 report on Form ADV data for investment advisers.
The number of advisers and total assets have increased dramatically.
From 2012 when Dodd-Frank implemented a change requiring fund managers to register the
Customer Identification Programs are coming for private fund managers
The Securities and Exchange Commission and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to have customer identification programs (CIPs). The proposed
The One With the Career Advice Becoming Insider Trading
You’re sitting poolside sipping on margaritas with your buddy. You’ve always wanted to work together and your buddy says that now would be a good time to do so. You ask, what about your current position. Your buddy, with a
Initial Observations Regarding Advisers Act Marketing Rule Compliance
With the issuance of the Marketing Rule for Investment Advisers (Rule 206(4)-1) decades of interpretations and guidance were wiped out. We’ve been waiting to see what falls under those seven general prohibitions in the Marketing Rule. We’ve been thirsting for
Another Fund Manager Falls Victim to a Political Contribution
Another fund manager was heavily fined for an employee making a political contribution. Wayzata Investment Partners had to pay a $60,000 fine.
The Minnesota State Board of Investments made $300 million in commitments to Wayzata funds from 2007 to 2013. In
Compliance Bricks and Mortar for April 26
I haven’t published one of these in a while. Here are a bunch of compliance-related stories that recently caught my attention.
In Silicon Valley, You Can Be Worth Billions and It’s Not Enoughby David Streitfeld in The New York
A Reminder that Hypothetical Performance Does Not Belong on Your Website
The Securities and Exchange Commission brought actions five investment advisory firms for violations of the Marketing Rule. The firms posted advertisements that included hypothetical performance on their websites.
The SEC points out that websites are available to the general public
Who knows what evil lurks in the hearts of men? The Shadow knows!
It survived motions to dismiss, summary judgment and now has survived a jury. The Securities and Exchange enlargement of insider trading, shadow trading, stuck through the case against Matthew Panuwat.
The SEC alleged that Mr. Panuwat traded in the