News & Analysis as of

CFTC Publishes Long-Awaited JOBS Act Relief

The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more

Court of Appeal Says Communications on Personal Communicating Devices are Exempt from Disclosure under Public Records Act

Reversing a Superior Court ruling that had caused quite a splash a few months ago, in City of San Jose v. Superior Court (H039498, March 27, 2014), the Sixth District of the Court of Appeal has held that communications to and...more

Plans for UK Public Register of Company Beneficial Ownership

In June 2013 we provided an update on proposals by the UK Government to establish a more rigorous transparent disclosure regime relating to ownership of UK incorporated companies, including their beneficial ownership. While...more

Proposed New Prospectus Exemption For Distributions To Existing Security Holders Of TSX-V Issuers

On November 21, 2013, the securities regulatory authorities in all Canadian jurisdictions, with the exception of Ontario and Newfoundland and Labrador (the “Participating Jurisdictions”), published for comment Multilateral...more

SEC Proposes Sweeping Amendments to Rules Governing Money Market Funds

The U.S. Securities and Exchange Commission (SEC or Commission) on June 5, 2013 proposed for public comment sweeping amendments to Rule 2a-7 under the Investment Company Act of 1940 and other rules relating to money market...more

AIFMD: Update for non-EEA fund managers

From 22 July 2013, the Alternative Investment Fund Managers Directive (2011/61/EU) (the “Directive”) and the supplementary level 2 Regulation (EU) No 231/2013 (the “Regulation”) will come into effect. This legislation will...more

Pennsylvania Office of Open Records Blasts Charter Schools

Charter school managers and officials should be aware that the Executive Director of Pennsylvania’s Office of Open Records has recently made public statements criticizing charter schools that take the position that they...more

FINRA Releases Public Offering FAQs

FINRA, the largest independent regulator for all securities firms doing business in the United States, has released a set of FAQs relating to its review of public securities offerings filed on its Public Offering Filing...more

CFPB Proposes Trial Consumer Disclosure Program

On December 13, as part of its Project Catalyst, the CFPB proposed a new policy that will allow financial institutions to conduct trial consumer disclosure programs. Participating firms would receive time-limited exemptions...more

A.G. Schneiderman Announces New Electioneering Disclosure Requirements for Nonprofits

On December 12, 2012, New York Attorney General Eric Schneiderman announced new proposed disclosure rules for New York-registered nonprofits designed to bring more transparency to electioneering activities by tax-exempt,...more

CFPB proposes policy to allow trial disclosure programs

The CFPB has issued a proposed policy under which it would exempt individual companies, on a case-by-case basis, from current federal disclosure requirements to allow those companies to test trial disclosures....more

Dodd-Frank Act Securitization Reform; New SEC ABS Office

On July 15, 2010, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd- Frank Act”), which include a number of provisions that will significantly impact the securitization industry. The Act...more

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