Self-Reporting

News & Analysis as of

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

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

SEC Extends Municipalities Continuing Disclosure Cooperation Initiative Self-Reporting Deadline For Issuers and Obligated Persons...

The Securities and Exchange Commission released a statement on July 31, 2014, modifying certain aspects of its Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”). The MCDC Initiative provides...more

SEC Enforcement Division Modifies Municipalities Disclosure Initiative

On July 31, the SEC announced modifications to its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative that will (i) allow issuers and obligors more time to complete their reporting requirements by extending...more

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

SEC Extends the MCDC Initiative Self Reporting Deadline

The Securities and Exchange Commission (“SEC”) just announced modified provisions of the Municipal Continuing Disclosure Cooperation Initiative (“MCDC Initiative”) that extends the self-reporting period for issuers and...more

SEC Modifies MCDC Initiative

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

SEC Makes Modifications to Municipalities Continuing Disclosure Cooperation (MCDC) Initiative

The Securities and Exchange Commission (SEC) recently announced modifications to its Enforcement Division’s Municipalities Continuing Disclosure Cooperation (MCDC) Initiative. First, the SEC has extended the deadline from...more

Industry Concerns Prompt SEC To Modify MCDC Initiative

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

Federal Register Round Up – June/July 2014

DOD Proposed Rules Seeking Contractor Business System Rule Self Assessments - The Department of Defense issued a proposed rule on July 15th that would revise the DFARS Business Systems Rule by requiring contractors...more

The Clock is Ticking on the SEC’s MCDC Initiative - Limited Self Reporting Window Closes September 9, 2014

The U.S. Securities and Exchange Commission (the “SEC”) has announced its Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”) for municipal issuers, conduit borrowers, other obligated persons...more

Low-Tech Proof In a High-Tech World: Northern District of California Denies Class Certification In Hulu Data Privacy Case

On June 16, the Northern District of California denied a motion for class certification in In re Hulu Privacy Litigation, No. C 11-03764 LB, ECF No. 111. The plaintiffs in that action alleged that Hulu violated the Video...more

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

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

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

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

CME Launches Website Links for Complaints and Self-Reports

CME Group’s website has added hyperlinks that allow persons to file complaints or self-report potential rule violations. ...more

Comments Due for New Expedited Review Process for CMS's Voluntary Self-Referral Disclosure Protocol (SRDP)

The creation of the SRDP through the Affordable Care Act as a mechanism to resolve potential Stark violations was welcomed by the industry. However, since enactment of the regulations implementing the SRDP in 2010, the volume...more

SEC Launches Cooperation Initiative to Encourage Municipal Issuers and Underwriters to Self-Report Continuing Disclosure...

On March 10, 2014, the Securities and Exchange Commission ("SEC") announced that issuers and underwriters of municipal securities may voluntarily report materially inaccurate statements made in offering documents regarding...more

SEC Initiative Encourages Continuing Disclosure Violation Self-Reporting By Issuers And Underwriters

HIGHLIGHTS - - The Municipalities Continuing Disclosure Cooperation Initiative (MCDC Initiative) begun by the SEC's Enforcement Division encourages issuers, borrowers or underwriters to self-disclose potential...more

SEC Encourages Self-Reporting of Continuing Disclosure Misstatements

In an effort to increase enforcement of continuing disclosure obligations, the Securities and Exchange Commission (“SEC”) announced a self-reporting program on March 10, 2014, referred to as the Municipalities Continuing...more

SEC Enforcement Division Encourages Self-Reporting by Municipal Securities Issuers and Underwriters

Yesterday, the Securities and Exchange Commission’s (SEC) Enforcement Division introduced an initiative to encourage self-reporting by municipal securities issuers and underwriters of possible securities law violations...more

OFCCP’s New Voluntary Self-Identification Requirements

Federal contractors must invite job applicants and employees to voluntarily self-identify as individuals with disabilities using a form that was recently released by the Office of Federal Contract Compliance Programs (OFCCP)....more

Federal Contractor Affirmative Action Regulations Take Effect March 24, 2014

New regulations issued by Department of Labor's Office of Federal Contract Compliance Programs take effect March 24, 2014. Requirements include establishing hiring benchmarks for veterans and adopting utilization goals for...more

CFPB’s New ‘‘Responsible Conduct’’ Guidelines: Will They Incentivize Greater Self-Reporting And Self-Regulation By Consumer...

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB or the Bureau) issued CFPB Bulletin 2013-6, titled ‘‘Responsible Business Conduct: Self-Policing, Self-Reporting, Remediation, and Cooperation.’’ The CFPB...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

FHA Issues Mortgagee Letter Clarifying Lender Self-Reporting Requirements

Possibly in response to the CFPB's recent emphasis on self-reporting, FHA issued Mortgagee Letter 2013-41 last week, which clarifies the self-reporting requirements for Single Family FHA-approved lenders. Ballard Spahr has...more

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