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On October 27, 2016, the U.S. Department of Labor (DOL) issued initial guidance on its new fiduciary rules, which are scheduled to become effective on April 10, 2017. The guidance was issued in the form of FAQs and is...more
The SEC recently released a proposed rule pursuant to Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) with respect to the implementation of incentive-based compensation arrangements...more
This post continues our examination of the Department of Labor’s suite of final fiduciary and conflict of interest regulations. Our prior posts discussed the newly expanded definition of “investment advice fiduciary” and the...more
Financial regulators have proposed new rules limiting the incentive pay of employees and other service providers at financial institutions. The Dodd-Frank Act of 2010 prohibits incentive compensation that encourages...more
In a joint release, Office of the Comptroller of the Currency, Treasury; Board of Governors of the Federal Reserve System; Federal Deposit Insurance Corporation; Federal Housing Finance Agency; National Credit Union...more
Your good client, Avery Phillips, Chairman of the Board, calls you because he is considering engaging a friend, Tepper, to identify potential investors for his company. Phillips explains that Tepper has extensive business...more
One of the goals of the JOBS Act was to encourage the development and use of platforms that permit accredited investors to invest in early stage and other private companies. The JOBS Act contains a provision that expressly...more