INTRODUCTION - Behaviors such as excessive pricing and refusal to supply are often well understood to create potential issues if the company is dominant. However, under the national laws of some EU member states, such conduct...more
The pandemic coronavirus (COVID-19) has significantly disrupted certain industries and markets, and captured the attention of market participants. This client alert reviews the March 4, 2020 SEC guidance issued in response to...more
On February 28, 2019, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission (“SEC”) issued a no-action letter to the Independent Directors Council (“IDC”) that provides boards of...more
On October 12, 2018, the staff of the Division of Investment Management (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued a no-action letter to the Independent Directors Council (“IDC”) (“IDC Letter”)...more
On May 1, 2017, the Securities and Exchange Commission (“SEC”) settled an enforcement action against a fund adviser and distributor for causing the funds to pay, outside of a Rule 12b-1 plan, for activities primarily intended...more
On April 25, 2017, the Financial Industry Regulatory Authority, Inc. (“FINRA”) released a Regulatory Notice titled Social Media and Digital Communications: Guidance on Social Networking Websites and Business Communications...more
On January 6, 2016, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management issued its first written guidance (“New Guidance”) on payments made by mutual funds to intermediaries for distribution and...more
The Securities and Exchange Commission (“SEC”) on September 21, 2015, brought the first of its long-awaited “distribution in guise” cases against a mutual fund adviser and distributor. The case follows a number of warnings...more