Corporate and Financial Weekly Digest - October 7, 2011


In this issue;

- SEC to Hold Roundtable to Discuss Conflict Mineral Rulemaking

- SEC Staff Issues Risk Alert on Master/Sub-account Risks

- Fraudulent Statements That Maintain Inflated Price Can Support Securities Fraud Claims

- Provision of Credit Card Receipt Is Not A “Publication” That Triggers Duty To Defend

An excerpt from "SEC Staff Issues Risk Alert on Master/Sub-account Risks"

A master/sub-account arrangement exists where the same beneficial owner maintains multiple sub-accounts; the beneficial ownership interests in the various sub-accounts may or may not be identified to a broker-dealer. On September 29, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations released a National Exam Risk Alert (the Alert) on risks associated with master/sub-account arrangements. In the Alert, the SEC’s National Exam Program (NEP) identified a number of potential risks associated with master/sub-account arrangements. Specifically, NEP identified the following potential risks..

Please see full newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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