The allocation of trades has always been an area of concern to hedge funds. The issue is whether a manager is breaching its fiduciary duties by favoring one fund or account over another. The reason this issue is so problematic is that it is so hard to define. For example, consider these scenarios: *If a manager’s funds have different investment [...]
JG ADVISORY SERVICES ANNOUNCES THAT THE PWG TECHCHECK©; ONLINE BEST PRACTICES ASSESSMENT TOOL FOR HEDGE FUNDS BASED ON THE PRESIDENT’S WORKING GROUP REPORT NOW REFERENCES HFSB STANDARDS JG Advisory Services LLC announced today that its online, self-assessment checklist based on the Report of the Asset Managers’ Committee to the President’s Working Group (PWG) on Financial Markets now [...]
You may have noticed that we haven’t posted any blogs lately. That’s because we have been just overwhelmed with the sheer volume of information, particularly on the hedge fund scandal front — not to mention the regulatory front! But for this post, we wanted to keep it simple and focus on a lesser-known recent news story that brings into focus [...]
The holiday season is upon us! What better time for hedge fund compliance professionals to revisit their gift-giving and gift-receiving policies! The over-arching compliance issue around gifts is that they should not result in, or even give the perception of, a conflict of interest. An example of this would be excessive gift giving from a [...]
As the worldwide economic crisis gets sorted out piece by piece, on the hedge fund regulation front, we see some common themes emerging worldwide as well. The Securities and Futures Commission of Hong Kong issued a Circular on October 27 listing a number of concerns regarding hedge funds. Here’s a sampling: -Hedge Funds should [...]
Over the past weeks of market turmoil, we have seen reports of hedge funds taking large defensive cash positions in order to preserve capital. For example, the Wall Street Journal reported earlier this week that Steve Cohen’s SAC Capital is half in cash and other short term instruments. While understandable, compliance professionals need to be alert [...]
The resignation of David Aufhauser as General Counsel of UBS’s Investment Banking Division this week raises an important compliance question: who, if anyone, at UBS was reviewing his personal trading? Did UBS have a complete “circle of review” such that even the top executives doing the reviewing were themselves being reviewed? Mr. Aufhauser resigned after [...]
We have developed an industry-leading online self-assessment questionnaire reflecting the President Working Group Asset Manager’s Best Practices Guidelines. The questionnaire asks a series of yes/no questions based on the guidelines presented in the report, and tabulates your own, as well as comparative, results at the end in a pdf output. It allows for comments as well. Of course, the [...]
When hedge funds put up their “gates” on redemptions, limiting the amount or timing of investor redemptions from a fund, compliance professionals need to get their antennae up for potential issues. With gates going up more frequently throughout the industry, it is interesting to see why some managers actually succeed in doing so, and others [...]
Emails and IMs can be dangerous — litigators, regulators and compliance professionals all know this well — yet their use at hedge funds, sometimes in the most casual of ways, continues to expand exponentially. Most recently, we have seen the emails on display in The Children’s Investment Fund litigation related to its CSX investment in which Christopher [...]
