On March 12, 2025, the SEC’s Division of Corporation Finance issued guidance affirming that issuers in a 506(c) offering could reasonably be considered to have properly "verified" an investor's accredited status based simply...more
The Alabama Securities Commission recently issued an Order exempting Alabama based investment advisers to “private funds” from the requirement to register as investment advisers with the ASC....more
The U.S. Securities and Exchange Commission has adopted amendments to the increasingly utilized “internet adviser exemption.” The exemption, originally adopted in 2002, has fostered the utilization of digital platforms for...more
The Financial Regulatory Authority (FINRA) recently identified the “initial themes” observed in a targeted examination of retail communications by member firms with respect to crypto assets. The headline grabbing statistic:...more
The North American Securities Administrators Association (NASAA) recently released a report prepared by its Broker-Dealer Section Committee (Committee) presenting the findings of Phase II (B) of its National Examination...more
On Jan. 10, 2023 the Financial Industry Regulatory Authority (FINRA) published its 2023 Report on the Examination and Risk Monitoring Program. This year, for the first time, FINRA introduced a financial crimes section in the...more
No later than November 4, 2022, investment advisers must have implemented measures necessary to comply with the amended Advisers Act Rule 206(4)-1(i.e., the “Marketing Rule”). Recently, the SEC’s Division of Examinations...more