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ISS Thinks Only Those Who Vote “No” Have A View

ISS Calls For Comments The ISS Global Policy Board is inviting comments on its benchmark proxy voting guidelines.  The comment period has been extended to November 7, 2011.  Here is a listing of the policies changes put out for comment. Today, I want to comment on ISS’ approach to Board responses to management say-on-pay (MSOP) votes.  ISS…

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Truth Endures For All Generations And Perhaps So Can A Family Office

Many rich people establish “family offices” to provide investment advisory services to family members.  Section 409 of the Dodd-Frank Act excludes “family offices” from the definition of “investment adviser” under the Investment Advisers Act of 1940.  Congress left it up to the Securities and Exchange Commission to define who is and who isn’t family for purposes of the family office exclusion.…

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SEC Slays Redwoods At Fearsome Pace

Yesterday, was a big day for both the regulated and the unregulated adviser industry. “The very rich are different from you and me . . . they have more money” The Securities and Exchange Commission adopted its final “family office” rules.  According to the SEC, “family offices” are established by wealthy families to manage their riches,…

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SEC’s Proposed “Family Office” Rule and Rule 260.204.9

In The Snows of Kilimanjaro, Ernest Hemingway wrote: “‘The very rich are different from you and me.’ And how someone had said to Julian, ‘Yes, they have more money.’”   That is certainly true in the case of the families described in the Securities and Exchange Commission’s recently proposed family office rule. According to the SEC,…

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