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Disclosure Requirements Securities and Exchange Commission (SEC) Self-Reporting

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series | SEC Enforcement: Recent Trends and What to Expect - October 26th, 12:00 pm - 1:00 pm...

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As we enter the final quarter of 2023, the US Securities and Exchange Commission (SEC) continues to maintain an aggressive enforcement agenda. Looking ahead to 2024, companies should expect more of the same. In this webinar,...more

Ballard Spahr LLP

The SEC’s Recent Personal Device Settlements Shed Light on the Question of Self-Reporting

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Summary - Two more broker-dealers became the latest financial institutions to settle with the SEC for failing to maintain and preserve electronic communications. What distinguishes these settlements from the 17 prior...more

Keating Muething & Klekamp PLL

Recent SEC Enforcement Actions Highlight Continuing Disclosure Obligations of Municipal Bond Underwriters

On September 13, 2022 the Securities and Exchange Commission filed litigation against four separate municipal securities underwriters for failing to comply with municipal bond offering disclosure requirements. The four firms...more

Carlton Fields

SEC Pressures Advisers on Undisclosed Conflicts

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We are actively looking for circumstances where an adviser is financially conflicted by incentives that could affect investment recommendations to clients. ... And I will tell you: the more we look, the more undisclosed or...more

Faegre Drinker Biddle & Reath LLP

The SEC Files Another Litigated Disclosure Case – With More Violations

On August 29, 2019, the SEC filed a complaint against a registered investment adviser alleging failures to disclose four categories of conflicts of interest and seeking disgorgement of $10 million in undisclosed compensation....more

Kramer Levin Naftalis & Frankel LLP

SEC Sues Investment Adviser for Nondisclosure of Revenue Sharing Agreement Details

On Aug. 1, the Securities and Exchange Commission (the SEC) charged Commonwealth Equity Services LLC, dba Commonwealth Financial Network (Commonwealth), a registered independent investment adviser to private clients (but not...more

Dechert LLP

SEC Announces Results of Share Class Selection Disclosure Initiative

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The Securities and Exchange Commission announced on March 11, 2019 that it had settled charges against 79 investment advisers in connection with its Share Class Selection Disclosure Initiative (SCSD Initiative). This...more

Jones Day

SEC's Focus on Retail Investors Targets Financial Conflicts of Interest

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Initial results of the SEC's Share Class Disclosure Initiative indicate a heightened focus on disclosures made to retail investors and consequences for any failure to self-report. On February 12, 2018, the U.S. Securities...more

Eversheds Sutherland (US) LLP

The other shoe has dropped – The SEC follows up with firms that didn’t self-report under the share class initiative

The Share Class Initiative - On February 12, 2018, the Division of Enforcement of the US Securities and Exchange Commission (SEC) announced the Share Class Selection Disclosure Initiative (Initiative), which informed SEC...more

WilmerHale

SEC Share Class Selection Disclosure Initiative: Practical Considerations and Lessons Learned

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The Securities and Exchange Commission (“SEC”) has made a concerted effort over the last several years to address investment advisers’ conflicts of interests and to establish standards for associated disclosure failures...more

Dechert LLP

SEC Announces Share Class Selection Disclosure Initiative

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The Division of Enforcement (Division) of the U.S. Securities and Exchange Commission (SEC) on February 12, 2018, announced a Share Class Selection Disclosure Initiative (SCSD Initiative). Led by the Division’s Asset...more

BakerHostetler

New SEC Enforcement Initiative Encourages Advisers to Self-Report Mutual Fund Share Class Violations

BakerHostetler on

On February 12, 2018, the Division of Enforcement of the U.S. Securities and Exchange Commission (“SEC”) announced a new initiative to encourage advisers to self-report share class violations. Share class violations occur...more

Dorsey & Whitney LLP

SEC Targets Advisers With New Cooperation Initiative

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The SEC’s Division of Enforcement announced a new cooperation initiative addressed to investment advisers who have failed to disclose conflicts arising from the receipt of 12b-1 fees from mutual funds. In essence, the...more

Goodwin

Financial Services Weekly News - September 2017 #3

Goodwin on

Editor's Note - Cybersecurity Returns to Center Stage. The Equifax breach and recent news that the Securities and Exchange Commission’s (SEC) EDGAR test filing system was hacked in 2016 have brought cybersecurity back to...more

Orrick, Herrington & Sutcliffe LLP

SEC Brings Post-MCDC Enforcement Actions Against Underwriter and Officials

On April 5, 2017 the SEC released two orders instituting cease-and-desist proceedings (consent decrees) which are the first post-MCDC cases finding securities law violations based on misstatements in official statements...more

Ballard Spahr LLP

SEC Announces Second Wave of MCDC Enforcement Actions

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The Securities and Exchange Commission (SEC) this week announced enforcement actions under its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative, targeting 22 municipal bond underwriting firms for alleged due...more

Eversheds Sutherland (US) LLP

SEC Announces First Charges Against Underwriters under MCDC Initiative

On June 18, the U.S. Securities and Exchange Commission (SEC) announced enforcement actions against 36 municipal bond underwriters, the first enforcement actions against underwriters brought by the SEC under the...more

Butler Snow LLP

The MCDC Initiative: December Was Just The Beginning

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As many of our issuer clients know, as a result of perceived wide-spread violations of post issuance reporting compliance, in 2014 the SEC conducted its “Municipal Continuing Disclosure Compliance Initiative” or the “MCDC...more

Bond Schoeneck & King PLLC

Deadlines Applicable to Colleges and Universities Approaching for Participation in SEC’s Continuing Disclosure Cooperation...

On March 10, 2014, the Securities and Exchange Commission (“SEC”) announced a voluntary self-reporting program for issuers and underwriters of municipal bonds for reporting of inaccurate statements made in offering documents...more

Sherman & Howard L.L.C.

Update: SEC Extends Deadline for Issuers to Participate in SEC’s Municipalities Continuing Disclosure Cooperation (MCDC)...

The Securities and Exchange Commission (SEC) has extended the deadline for issuers and obligors to self-report potential violations of their continuing disclosure obligations from the original deadline of September 10, 2014...more

Shumaker, Loop & Kendrick, LLP

SEC Modifies MCDC Initiative in Response to Industry Concerns

On July 31, 2014, the Securities and Exchange Commission extended the Municipalities Continuing Disclosure Cooperative Initiative (“MCDC”) deadline to allow issuers and obligors more time to complete their reporting...more

Holland & Knight LLP

SEC Modifies MCDC Initiative

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On July 31, 2014, the Securities and Exchange Commission (SEC) issued a press release regarding an extension of the deadline for its Municipalities Continuing Disclosure Cooperation initiative (MCDC). The extended deadline...more

Ballard Spahr LLP

Industry Concerns Prompt SEC To Modify MCDC Initiative

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In response to concerns raised by industry participants, the Securities and Exchange Commission (SEC) has made some modifications to its Municipalities Continuing Disclosure Cooperation Initiative (MCDC Initiative). The SEC...more

Saul Ewing LLP

SEC’s Self-Reporting Program to Correct Misstatements Regarding Continuing Disclosure Compliance Set to Expire on September 10,...

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The Securities and Exchange Commission’s Municipalities Continuing Disclosure Cooperation Initiative provides an opportunity for municipal bond issuers, borrowers and underwriters to correct misstatements in offering...more

Miller Canfield

New SEC Initiative Offers Municipal Issuers and Underwriters an Exit Strategy for Continuing Disclosure Violations

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The U.S. Securities and Exchange Commission Enforcement Division recently announced a program intended to resolve violations of federal securities laws regarding continuing disclosures in bond offering documents. The program,...more

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