Disqus - Latest Comments for dougcornelius

Re: Prague

Doug Cornelius — Thu, 12 Jun 2025 11:27:37 -0000

Great city. The fantastic assortment of historic buildings remain due to the lack of bombing and battles near Prague, or in most of Czechia.

Re: Gov. Baker Signs Distracted Driving Bill Into Law

Doug Cornelius — Tue, 26 Nov 2019 11:01:05 -0000

Please also point out the law prohibits using your device at red lights.

Section 13B. (a) No operator of a motor vehicle shall hold a mobile electronic device. No operator of a motor vehicle shall use a mobile electronic device unless the device is being used in hands-free mode. No operator of a motor vehicle shall read or view text, images or video displayed on a mobile electronic device; provided, however, that an operator may view a map generated by a navigation system or application on a mobile electronic device that is mounted on or affixed to a vehicle’s windshield, dashboard or center console in a manner that does not impede the operation of the motor vehicle. For the purposes of this section, an operator shall not be considered to be operating a motor vehicle if the vehicle is stationary and not located in a part of the public way intended for travel by a motor vehicle or bicycle. https://malegislature.gov/L...

Re: /Filmcast Ep. 404 - Rings

Doug Cornelius — Thu, 09 Feb 2017 18:57:57 -0000

Best sports film? Where is the love for Field of Dreams! Want to play catch <tears flow="">

Re: Academic blogging versus academic self publishing?

Doug Cornelius — Tue, 06 Dec 2016 11:15:46 -0000

It's easier to fill your your shelf with books than blog posts.

Re: TRAFFIC ALERT: Walnut Street Closed Between Duncklee and Hillside

Doug Cornelius — Tue, 30 Aug 2016 17:39:18 -0000

It's a "crash" not an accident. You don't have any information to know if someone was at fault or negligent. Someone usually is.

Re: Stop Faxing

Doug Cornelius — Wed, 11 May 2016 13:14:27 -0000

One counterpoint is that Massachusetts, with one of the strictest data privacy laws, considers faxes to be secure communications but no so for email.

Re: Enterprise 2.0, Finally?

Doug Cornelius — Thu, 20 Nov 2014 15:14:29 -0000

I'll echo number 3. It's the the death of blackberry and the bigger screens of smartphones and tablets. The webpage view of E2.0 failed on blackberries. Now that there is now screen space people can communicate on the go and not be limited to email.

Re: Conduct Versus Bureacracy, and Bureaucracy Won

Doug Cornelius — Tue, 08 Apr 2014 11:25:33 -0000

I agree with Minnesota Michael. I don't think the tax compliance at Caterpillar can be equated to the apparent failures at GM. Many international companies use a similar strategy. International tax arbitrage is nearly as common as state-level tax arbitrage.

Caterpillar made the problem worse with a paper trail of bad emails and the whistleblower issue.

Re: Non-accredited crowdfunding: a license to pillage the vulnerable, or democracy in action?

Doug Cornelius — Wed, 02 Apr 2014 11:09:59 -0000

The state level crowdfunding supports reinvesting back in your community. I think the fraud and trust concerns are somewhat lessened by the possibility that you may actual meet the people behind the company in person. Most non-sociopaths are less likely to de-fraud a person they've met or have a connection with.

Re: SEC official to angel community: go ahead, develop your own verification methods!

Doug Cornelius — Wed, 02 Apr 2014 08:46:49 -0000

For me, the bigger concern is the regulatory overhang. The SEC injected too much uncertainty into the fundraising process by releasing the proposed rules. That created a great deal of concern among potential issuers and potential investors.

I'm surprised that 506(c) even reached the 10% level mentioned in Higgins speech.

Re: Two Thoughts about Dewey LeBoeuf and Parallel Proceedings

Doug Cornelius — Thu, 20 Mar 2014 07:55:29 -0000

It seems really strange that a junior person like Warren was dragged into the criminal complaint. The SEC didn't deem him worthy for the civil complaint.

It's not to say he wasn't complicit. There are some bad emails in the complaints.

Re: SEC Charges Hao He with Insider Trading, for Some Reason or Another

Doug Cornelius — Tue, 11 Feb 2014 13:44:06 -0000

I think it's the case of the SEC shooting first and asking questions second. They see a suspicious trade, file to stop the loss of proceeds, and then try to find the connections. We saw this in the Badin case. http://www.secmiscellany.co...

In this case, He must have felt that the SEC would easily find the connection and settled.

Re: I <3 Securities Regulators

Doug Cornelius — Tue, 11 Feb 2014 12:51:12 -0000

The IRS has the easier task. There is only one Code and the IRS has only on mandate: collect revenue.

The SEC has to deal with several different Congressional Acts that cover a broad array of business models. It also has to balance two competing mandates: investor protection and capital formation. Rarely does anyone think the SEC gets the balance just right. The SEC also gets the blame for poorly drafted securities laws that come out of Congress that the SEC gets stuck trying to implement.

Re: RIP Sammy the Dog

Doug Cornelius — Fri, 07 Feb 2014 12:29:08 -0000

Sorry for your loss. A good dog is true companion and family member. I'm sure not having him around leaves a big hole in your life and in your heart.

Re: Real Lawyers Have Blogs is 10 years old : How I got started

Doug Cornelius — Tue, 26 Nov 2013 14:10:46 -0000

Congratulations on 10 years. Looking back, lots has changed and lots has stayed the same from the early days of blogging.

Re: Unexpected twist: SEC offers site for voluntarily submitting 506(c) materials

Doug Cornelius — Thu, 26 Sep 2013 15:44:38 -0000

Sara was apparently paying closer attention to the July 10 meeting and remembered that the SEC would be rolling out the portal.

The submission of solicitation materials is a ridiculous request, whether it's voluntary or mandated by the rule. There is little the SEC can do the submissions, unless it wants to hire a lot more staff to look at what comes in. I'm confused why the issuer's name is not a requirement.

There is still the core problem that the SEC is not providing a good definition of what "General Solicitation" is.

Re: Two fronts about to collide

Doug Cornelius — Sat, 21 Sep 2013 18:05:04 -0000

I would think that Angel groups could act as great source for verification under 506(c). The non-exclusive safe harbors are for unknown investors. The Angel groups could vouch that investor is accredited based on based investments and background.

The benefit of 506(c) is avoiding the foot-faults rather than actually engaging in mass-market advertising. By checking the (c) box, the company would have more freedom at demo days and to respond to media stories about the company.

I thing Angel groups should rethink their position, and think of ways they can help facilitate the verification process.

Re: Media Seeks Answers to General Solicitation

Doug Cornelius — Sat, 21 Sep 2013 18:01:25 -0000

Joe -

We can talk more about this on Monday, but the big problem was the definition of general solicitation and advertising. The SEC has done a poor job of sketching the boundaries and many well-accepted and low-risk-to-investor activities probably fell into that poorly defined boundary.

By lifting the ban, all sorts of advertising are permitted, most of which would be a poor return on time and money for issuers.

The public display of a pitch for securities was a great red flag for regulators. If they could see it, the issuer had poor advice or was a scam. They have lost that red flag.

The better approach would have been to craft some broad exceptions from the ban rather than lifting it. Now the SEC is monkeying with a market for capital formation that was very effective, even if flawed.

Re: The importance of Twitter being unimportant

Doug Cornelius — Fri, 13 Sep 2013 15:07:56 -0000

The New York Times is biased, of course. The paper gives stories importance based on where the editors place the story and how much space they allocate to it. That is true both in the physical paper, the website, and the app.

Email sits in your inbox with the most recent on top, without regard to its importance.

Google made its fortune by being able to sort the mess of web pages into a list based on those relevant to your search terms. Twitter seems to cherish the simplicity of not imposing relevancy.

most
recent on top, without regard to their importance. - See more at:
http://www.wac6.com/wac6/20...
most
recent on top, without regard to their importance. - See more at:
http://www.wac6.com/wac6/20...
most
recent on top, without regard to their importance. - See more at:
http://www.wac6.com/wac6/20...

Re: The 506(b)/506(c) distinction ain't binary

Doug Cornelius — Wed, 31 Jul 2013 12:28:06 -0000

I think it's too early to be "firing the cannon" on which election to make. For me, a lot will depend on the final changes to the filing requirements for Form D and the filing of advertisements.

I don't think the legends requirement is a big deal. Most of those are already in offering materials in one form or another.

From the private fund perspective (your East Coast perspective) in the end it comes down to the flexibility offered by 506(c) against the additional compliance costs.

Re: A New Beginning at Shipman & Goodwin LLP

Doug Cornelius — Mon, 29 Jul 2013 10:50:12 -0000

Congratulations on the new opportunity.

Re: "Do no harm"

Doug Cornelius — Thu, 11 Jul 2013 13:08:41 -0000

That new proposed Form D rule was an unexpected and unwanted surprise. Two inches of new regulations making it harder to raise capital.

Re: Doug Cornelius on the accredited investor definition post-DOMA

Doug Cornelius — Mon, 01 Jul 2013 13:16:54 -0000

The item that caught my attention in the proposed rule release for verification of accredited investor status was that an investor questionnaire by itself might not be enough of a reasonable step. If that stays in the final rule, issuers will presumably need some sort of income statement or wealth statement from a third party.

If an investor checks that box that he or she has a combined income with a spouse that meets the accredited investor income threshold, an issuer may need to see a statement of that combined income. As of today, it would not be a joint income tax filing because DOMA prevented that in past tax years. What do you do if you see something that indicates its a same sex couple?

Re: The accredited investor definition, after the Supreme Court strikes down DOMA

Doug Cornelius — Wed, 19 Jun 2013 16:03:42 -0000

Could? yes. Will? I doubt it.

I don't see staff acting without approval of the commissioners on something as controversial as recognizing same sex marriage. I'm skeptical that they would embrace this political hot potato when they have so much other Congressionally-mandated activity they need to address.

Re: The accredited investor definition, after the Supreme Court strikes down DOMA

Doug Cornelius — Wed, 19 Jun 2013 08:23:32 -0000

I don't see the SEC throwing itself on the same-sex landmine by rushing out a rulemaking when it still has not yet lifted the ban on general advertising and solicitation.