Analysis of cutting-edge securities industry issues
The late great comedian, George Carlin, was made famous by his routine, “The Seven Dirty Words You Can Never Say On Televisions”. Likewise, fraudsters do not want compliance personnel to…
Continue Reading The Thirteen Dirty Secrets That A Fraudster Does Not Want You To Know?
A simple review of FINRA’s enforcement proceedings demonstrates a new norm; compliance officers are being held accountable as supervisors for rules violations. How can a compliance officer avoid being held…
Continue Reading Who Else Wants To Avoid Being Considered A Supervisor?
At least, they can the health care and environmental arenas. Under the responsible corporate officer (RCO) doctrine, the ability to control corporate conduct is sufficient to hold officers criminally liable…
Big news out of Europe today (besides fears of a Greek exit from the Euro returning like a slasher flick monster that just won’t die): Michel Barnier, the EU’s top…
In its never ending quest to find suitable ways to address capital formation issues in the United States, the SEC’s Division of Corporation Finance is looking to see if foreign jurisdictions…
Continue Reading IS IT POSSIBLE TO FIND CAPITAL FORMATION SUCCESS OVERSEAS?
There was plenty of debate when the SEC adopted its new whistle blower bounty program. Many commentators thought that the program would result in an onslaught of whistle blowers directly…
Continue Reading The SEC Whistleblower Program May Have Spurred Corporate Reform
Today’s Wall Street Journal includes a story (subscription required) of an attorney for the SEC inadvertently “outing” a whistleblower while interviewing an executive of the whistleblower’s former employer. The SEC…
Continue Reading When the Government Blows the Whistle on a Whistleblower
Recently, the SEC announced that it would take steps to bar felons and bad actors from any Regulation D offering.
This rule was mandated by the Dodd-Frank Act, and the…
Continue Reading No More Felons and Other Bad Guys in Regulation D Offerings
Ernie will be moderating a panel on investigating and responding to data breaches. The discussion will include the required specialized skills and active coordination with a company’s IT personnel and external IT…
Recently, the SEC’s Division of Corporation Finance Director indicated that the SEC was reviewing certain issues in an attempt to assist small businesses with capital formation.
The SEC is assessing…
