Daniel A. Nathan

Daniel A. Nathan

Morrison & Foerster LLP

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Investment Management Legal + Regulatory Update -- September 2014

In This Issue: - Regulation: Long-Awaited Money Market Fund Rules Adopted - SEC Staff Offers Guidance Regarding Investment Advisers and Proxy Advisory Firms - SEC Staff Closes Loophole on BDC Asset...more

9/17/2014 - Banks CFTC Conflicts of Interest CPO Dodd-Frank Enforcement Actions FINRA Hedge Funds Investment Adviser Liquidity Fees Money Market Funds Municipal Advisers NAV Pay-To-Play Proxy Advisors Redemption Gates SEC Strategic Enforcement Plan Whistleblowers

CFTC Again Charges Civil Perjury – This Time for Statements Made in an Off-the-Record Interview

On January 2, 2014, the US Commodity Futures Trading Commission (CFTC) ordered a Russian foreign national to pay a $250,000 civil penalty for making false and misleading statements to CFTC staff in an interview during an...more

1/14/2014 - CFTC Commodities Exchange Act Dodd-Frank False Statements Off-the-Record Perjury

CFTC Proposes Speculative Position Limits – Again

On November 5, 2013, the Commodity Futures Trading Commission (“CFTC” or “Commission”) proposed new speculative position limits. The proposal (“New Proposal”) would establish spot-month and non-spot-month limits for 28 core...more

11/20/2013 - CFTC Compliance Dodd-Frank Futures Position Limits

Halloween Shivers: Frightening Times Ahead for RIAs?

Two Halloween announcements by securities regulators may frighten investment advisers. The October 31 statements from the SEC and the North American Securities Administrators Association (NASAA) suggest that federal and...more

11/5/2013 - Compliance Dodd-Frank NASAA OCIE SEC

The Impact of the SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Broker-Dealers and Investment...

The SEC recently finalized amendments to Rule 506 of Regulation D and Rule 144A under the Securities Act relaxing prohibitions against general solicitation in certain private offerings of securities implementing Section...more

9/12/2013 - Bad Actors Broker-Dealer Dodd-Frank FINRA General Solicitation Investment Adviser JOBS Act SEC

SEC to Broker-Dealers: More Oversight, Fewer Madoffs?

The Securities and Exchange Commission (SEC) published a Final Rule last week amending certain annual reporting, audit, and notification requirements for broker-dealers in the broker-dealer reporting rule (Rule 17a-5) and the...more

8/8/2013 - Audits Bernie Madoff Broker-Dealer Dodd-Frank Fraud PCAOB SEC

SEC and CFTC Issue Identity Theft Rules

Today, April 19, 2013, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) published in the Federal Register rules and guidelines requiring their respective regulated financial...more

4/22/2013 - CFTC Cybersecurity Data Protection Dodd-Frank FCRA Identity Theft SEC

Will the CFPB Take on the Regulation of Retirement Savings Plans?

According to a recent Bloomberg report, the Consumer Financial Protection Bureau is considering whether it should take a role in helping Americans manage their retirement savings. CFPB Director Richard Cordray told a...more

2/26/2013 - CFPB Dodd-Frank DOL FINRA Retirement Richard Cordray Savings Plans SEC

Financial Services Report -- Winter 2012

In This Issue: Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report. Excerpt from the Bureau Report: World’s Most...more

12/18/2012 - American Express CFPB Chase Bank Cybersecurity Debt Collection Dodd-Frank FDIC FTC Google Mobile Apps MySpace Project Catalyst Stress Tests TILA

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