Tag Archives | enforcement

Turnkey Governance Problematic at Northern Lights

Some trusts are created as turnkey mutual fund operations that launch numerous funds to be managed by different unaffiliated advisers and overseen by a single board of trustees. The federal securities laws require all mutual fund directors to evaluate and approve a fund’s contract with its investment adviser, and the funds must report back to […]

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Corporate Directors Forum 2012 – Part 2: Robert Khuzami, SEC Director of Enforcement

These are some relatively quick notes that I’m sharing from the Corporate Directors Forum 2012, held on the beautiful campus of the University of San Diego, January 22-24, 2012. Since I am busy with no-action requests this proxy season, this post may be a cryptic… not complete sentences bt hopefully mor intelligible thN txt msgN. Keynote Speaker: Robert Khuzami, […]

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Video Friday: FCPA Compliance

SVNACD Avoiding the Crosshairs. A primer on anticorruption laws relevant to U.S. Companies, especially the Foreign Corrupt Practices Act (FCPA Discussion of the ramifications of the new whistleblower provision of the Dodd-Frank Act, particularly as it relates to FCPA enforcement Insight into the nuts and bolts of investigating FCPA allegations and dealing with the Department […]

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No One Knew it Existed: The SEC's Bounty Program

Since its inception in 1989, the SEC has paid out a grand total of $159,537. Five claimants have received money from the program since 1989, with one claimant taking home the bulk, $100k. The other four split $60,000. Bounty can’t exceed 10% of the amount recovered from a civil penalty but that limitation doesn’t seem […]

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