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Rather, when the Compliance Rule originally went into effect in 2004, the adopting release described only 3 elements that should be considered in an annual review: 1) compliance matters in the previous year (e.g., when compliance policies and procedures did or did not function as intended), 2) changes in business activities (e.g.,
However, the early 2000s were plagued by a variety of SEC enforcement actions that alleged fiduciary duty violations – primarily involving trading abuses by investment advisory personnel – which led the regulator to create a rule (that became effective in 2004) requiring all SEC-registered investment advisers to adopt and enforce a written (..)
In 2004, I set out to climb (conquer) Mount Rainier. I learned the hard way that you don’t “conquer” a mountain. My goal was to get that summit pic of me holding the ice axe over my head while congratulating myself and my teammates for this great achievement.
I have worked at Booz Allen and Hamilton, I’m a strategic planning guy. I get hired by Citibank in planning. This business is just starting. I write a businessplan for it. Like, 00:06:56 [Speaker Changed] Like, you know, it’s a business. All that said, you wrote the, the businessplan.
And so these were two stories, maybe three, before I’m 9-years-old of bad economics, bad culture, and a bad businessplan. By the way, there’s a difference between an entrepreneur and a businessman or a business woman. Different risk tolerance and different businessplan. They have a dumb businessplan.
And we were invited to pitch for the business of what was one of the most exciting hedge funds at the time. It was a spin out from, so this would have been 2004, spin out from a well-known prop group, to my point on doing work for a lot of the prop groups. We do case studies, idea pitches, mock portfolios, businessplans.
And I’m like, dad, I found I need 25 grand to get going and my dad said send me a businessplan. I went to business school RITHOLTZ: He just wanted you to go through the exercise. LINDZON: No, so obviously, I did the businessplan, I’m kidding. RITHOLTZ: 2004, 2005. RITHOLTZ: Yes. LINDZON: Yes.
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