FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs
Aboveground Storage Tanks: Where Are We Now?
Legal Minute: Cybersecurity Reporting Requirements for Government Contractors
Conflict Minerals Reporting Requirements
Connecting the Data Dots: Sapient’s Jim Bennett Talks Compliance Reporting
On June 26, 2015, the Securities and Exchange Commission (SEC) issued a guidance update on Rule 204A-1 of the Investment Advisers Act of 1940 (Advisers Act). Rule 204A-1 requires, among other things, certain advisory...more
The concept release seeks public comment on possible new reporting requirements focused on the audit committee’s responsibilities with respect to its oversight of the independent auditor. As the release notes, SOX mandated...more
The U.S. Securities and Exchange Commission recently proposed rules under the Investment Company Act of 1940 and related regulations that would require certain funds, including Exchange-Traded Funds, to provide additional...more
In a June 2015 Guidance Update, the staff of the Division of Investment Management clarified how the code of ethics reporting rules apply to investment advisers.
Current rules require certain advisory personnel who...more
On May 20, 2015, the Securities and Exchange Commission (“SEC”) proposed rules, forms and amendments under the Investment Company Act of 1940 (the “1940 Act”) and related regulations (together, the “Proposed Amendments”) that...more
On May 20, 2015, the Securities and Exchange Commission (“SEC”) issued a release proposing new rules and forms and amendments to existing rules and forms that would affect registered investment companies (the “Investment...more
In This Issue:
- A Summary Across Five Continents
- Law and Sanctions
- The Legislative Framework: Whistleblower Protections Across the Globe
- Global Differences: The Cultural...more
On May 20, 2015, the Securities and Exchange Commission (SEC) released several proposals, "Amendments to Form ADV and Investment Advisers Act Rules," that would require investment advisers to provide additional information on...more
In this episode I visit with Scott Killingsworth on the recent SEC enforcement action in the SFX matter. In that case, the SEC held the CCO personally liability. We discuss the underlying facts, prior SEC pronouncements the...more
The SEC has published 11 Compliance and Disclosure Interpretations related to Regulation A+ — numbered 182.01 through 182.11 under Securities Act Rules. Highlights are:
- Twitter is allowed for testing the waters! ...more
Regulation A+ goes into effect June 19, 2015, allowing funding of companies by non-accredited investors. Smaller companies can offer and sell up to $50 million of securities in a 12-month period, subject to eligibility,...more
An early review of conflict minerals filings for the 2014 reporting period shows improvement in “detail, clarity and quality,” according to this article in BNA. As reported by Elm Sustainability Partners, a conflict minerals...more
The U.S. Securities and Exchange Commission (SEC or Commission) unanimously approved a proposal (Proposal) to modernize the reporting of information provided by registered investment companies (funds). Guided by the recent...more
On May 20, the Securities Exchange Commission proposed changes to rules affecting the reporting and disclosure obligations of registered investment companies and advisers.
Investment Company Proposals: The SEC...more
FINCEN NAMES JAMES EL-HINDI AS NEW DEPUTY DIRECTOR -
On May 21, FinCEN announced Jamal El-Hindi as its new Deputy Director. Since January 2015, El-Hindi has been serving as the agency’s acting Deputy Director, and...more
The Securities and Exchange Commission has issued proposed rules (the Proposal) under the Investment Advisers Act of 1940, as amended, that would, among other things, expand the information collected on Form ADV, provide for...more
At an open meeting of the Securities and Exchange Commission today, Chair Mary Jo White announced to enhance SEC reporting by investment companies and investment advisers.
Data collection. The SEC proposed rules that...more
On May 20, 2015, the SEC proposed new and amended rules and forms (the “Proposals”) that, if adopted, will significantly broaden the type and scope of information reported by registered investment companies. The Proposals,...more
In late May, the Securities and Exchange Commission (the “SEC”) proposed rules that would amend portions of Form ADV and rules promulgated under the Investment Adviser Act of 1940 (the “Advisers Act”). The proposed amendments...more
On May 20, 2015, the Securities and Exchange Commission (SEC) unanimously approved a proposal of additional amendments to the Investment Advisers Act of 1940 (Advisers Act)1: specifically, three changes to Form ADV 1A, and...more
As the annual May 31 deadline falls on a Sunday this year, companies must file their Conflict Minerals disclosures under Section 1502 of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act with the U.S....more
If finalized, the proposed rule would be the SEC’s second major step toward finalizing the cross-border rules for security-based swaps under the Dodd-Frank Act.
On April 29, 2015, the US Securities and Exchange...more
Reporting and Blue Sky Issues -
For many years, SEC Regulation A languished as an exemption from registration that nobody really used. Although securities issued in a Regulation A offering are not “restricted...more
Proposals would impose new disclosure requirements designed to enhance the SEC’s ability to monitor the industry.
On May 20, the US Securities and Exchange Commission (SEC) unanimously approved proposals intended to...more
The U.S. Securities and Exchange Commission (SEC) today unanimously approved proposals (Proposals) to modernize the reporting of information provided by registered investment companies (funds) and registered investment...more
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