October 5, 2023- The Federal Deposit Insurance Corporation Board of Directors approved a Notice of Proposed Rulemaking on Proposed Guidelines Establishing Standards for.
Bernie Madoff Lives!
The man behind the world’s largest Ponzi scheme died at 82; the system that enabled his grift continues in his image.
Mario Tama/Getty Images
What also must be known about Bernie Madoff, who died on Wednesday at the age of 82, is that prior to the revelation in December 2008 that he had been running the world’s largest Ponzi scheme, he was, for most of his career, one of the most well-respected figures in finance. He was anything but marginal. He served as the chairman of Nasdaq three different years in the 1990s, and served on the boards of many Wall Street organizations. The funds he ran attracted some of the richest people in the world. His niece married the former assistant director of the Security and Exchange Commission’s Office of Compliance Inspections and Examinations. (In 2007, he bragged about a “very close” relationship with an SEC regulator. “My niece even married one,” he laughed.) He was an insider.
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (“
OCIE”) highlighted alternative data, or “alt data,” as a top examination priority.
1 AIMA held a webinar on November 17, 2020, for investment managers on OCIE’s use of alt data, entitled Alternative Data and OCIE: How, What and Why You Should Prepare Ahead of Your Next SEC Exam, led by Senior Advisor of Promontory Financial Group Jane Jarcho, Director of Promontory Financial Group Sarah Curran, Director of Promontory Financial Group Drew Weilbacher, as well as AIMA’s Senior Advisor, Suzan Rose.
1. Scrutinize Your Information Sources
The first takeaway is to scrutinize your information sources to identify your use of alt data providers, in particular, and how that data fits into the firm’s policies and procedures in relation to material nonpublic information (“
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The staff of the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (staff) issued a Risk Alert on November 19, 2020 (Risk Alert), related to OCIE’s observations regarding deficiencies in investment adviser compliance programs.
1 The Risk Alert is intended to share OCIE’s observations on “notable compliance issues” found in recent examinations of SEC-registered investment advisers (advisers) related to Rule 206(4)-7 (Compliance Rule) under the Investment Advisers Act of 1940, which issues are “among the most common cited by OCIE” according to the Risk Alert. The Risk Alert groups the staff’s observations into six categories: inadequate compliance resources; insufficient authority of Chief Compliance Officers (CCOs); annual review deficiencies; implementing actions required by written policies and procedures; maintaining accurate and complete information in policies and
Tuesday, December 15, 2020
OCIE”) highlighted alternative data, or “alt data,” as a top examination priority.
1 AIMA held a webinar on November 17, 2020, for investment managers on OCIE’s use of alt data, entitled Alternative Data and OCIE: How, What and Why You Should Prepare Ahead of Your Next SEC Exam, led by Senior Advisor of Promontory Financial Group Jane Jarcho, Director of Promontory Financial Group Sarah Curran, Director of Promontory Financial Group Drew Weilbacher, as well as AIMA’s Senior Advisor, Suzan Rose.
1. Scrutinize Your Information Sources
The first takeaway is to scrutinize your information sources to identify your use of alt data providers, in particular, and how that data fits into the firm’s policies and procedures in relation to material nonpublic information (“