Happy Halloween!
I love carving pumpkins on Halloween. Here is the one I did last night:
I love carving pumpkins on Halloween. Here is the one I did last night:
On September 26, 2002, Financial Crimes Enforcement Network issued a notice of proposed rulemaking, proposing to require unregistered investment companies to establish and implement anti-money laundering programs. (Anti-Money Laundering Programs for Unregistered Investment Companies, 67 FR 60617 (Sep. 26, 2002))
In that notice of proposed rulemaking, FinCEN proposed to define the term “unregistered investment company” as (1) an issuer that, but for certain exclusions, would be an investment company as that term is defined in the Investment Company Act of 1940, (2) a commodity pool, and (3) a company that invests primarily in real estate and/or interests in real estate. FinCEN proposed requiring these companies to file a notice so that FinCEN could readily identify such companies and require them to establish and implement anti-money laundering programs.
I have been watching that rule-making process because it could have a profound impact on buying and selling real estate. For big commercial transactions we keep an eye on the parties to see if there is a reason to be wary and to see if they on the Specially Designated Nationals and Blocked Persons List. But I had some concern that they could extend the “know your customer” rules deep into real estate transactions imposing lots of administrative overhead for little benefit.
Yesterday, FinCEN gave notice under 31 CFR Part 103 Withdrawal of the Notice of Proposed Rulemaking for Anti-Money Laundering Programs for Unregistered Investment Companies . FinCEN is not abandoning the possibility of pursing the rulemaking. Given the six year span since the notice, they feel it has gone stale. If (or when) they decide to proceed with an anti-money laundering program requirement for unregistered investment companies, they will publish a new notice.
Disclaimers
As I walk down the path of compliance and ethics, I continue to find lots of similarities with the themes behind knowledge management and social networks. One thing I have talked about in the past is the important of transparency. Being more open makes your work life and personal life more enriching. Networking is about what you put into the network. the more you put in, the more you get back. Transparency makes a network function better. A law firm and any business is a network.
I ran across a transcript from LRN of a presentation by Dov Seidman at the Center for Business Ethics at Bentley University: The Power of How: Achieving Enduring Success Through Ethics.
“Basically, in a world in which nothing stays hidden, you have to act as if you have nothing to hide. But before you can act as though you have nothing to hide, in fact, you must have nothing to hide. There is an opportunity to literally out-behave your competition.”
From the Boston Globe’s Green Blog: Oysters help clean the Charles River.
Oysters eat silt, in addition to the phytoplankton that drift in the currents. As they eat, they also ingest some of the bacteria and organic compounds contained in sewer overflow, which Jay said runs untreated into the Charles from houses and streets during heavy rains.
So the Massachusetts Oyster Project dropped 150,000 oysters into the Charles River Basin around Constitution Marina this past weekend.
Oysters may be able to offset point pollution sources such as partially treated sewage coming out from Combined Sewage Overflows (CSOs). The number, flow, and impact of these has been reduced dramatically by the work of the MWRA and the cleanup of Boston Harbor. But it will be difficult to totally eliminate CSOs entirely.
One of my earlier concerns about LinkedIn was that it was very static and was little more than an online rolodex. They just launched a new applications feature that could dramatically changed LinkedIn.
These applications allow you to pull content from other sources into your LinkedIn profile, making it much more dynamic. Just a few minutes ago I added the Blog Link Application. Now it is pulling in blog posts from the three listed on my profile: this blog, Real Estate Space and DougCornelius.com.
One of the reasons I liked Facebook was its ability to aggregate content about you from multiple sources. Now LinkedIn can do the same thing.
My second victim this Halloween:

And the Son with pumpkin number 2.

Thanks to the Pumpkin Lady for the Home Sweet Home pumpkin stencil.
My latest article has been published in National, the magazine of the Canadian Bar Association: Knowledge Management in a 2.0 World.(.pdf)
It’s never been more important for lawyers and law firms to be able to organize and access all their knowledge. And thanks to the emergence of Web 2.0 tools like blogs and wikis, it’s also never been easier. Welcome to the next generation of KM.
I take no credit for the French translation of the article. My french is not that good.
With the few days in between jobs, I gave back The Firm’s Blackberry and switched over to the iPhone. I love the rich screen and graphics. I love the rich development of applications for the iPhone.
Yesterday, Google released the Google Earth for the iPhone. For those of you who have not used Google Earth, it is a more robust use of the information you access in Google Maps.
For a real estate person like me, the ability to image locations and put an individual property in the context of a larger community is very powerful. One of the reasons I went into real estate two decades ago was the tangible quality of real estate. I am drawn by the relationship of individual pieces of property and how they relate to the other properties and activities around them.
Below is the introductory YouTube video from Google about Google Earth for the iPhone.