The holy grail (at least so far) of conflict minerals precedents was filed with the SEC albeit perhaps too late for many issuers to wholesale change course. But still excellent for a final form check. ...more
At the core, the court’s first amendment objection to the conflict minerals rules was that by requiring issuers to state its products have not been found to be “DRC conflict free” it compelled an issuer to “confess blood on...more
In a letter to the SEC Chair, Mary Jo White, Senator Edward J. Markey and a group of other Member of Congress urged the financial oversight agency to implement the rule requiring due diligence and reporting requirements on...more
On December 18, 2013, the SEC published its proposal to modify Regulation A. The SEC is proposing to expand Regulation A into two tiers: Tier 1, for offerings of up to $5 million; and Tier 2, for offerings of up to $50...more
12/31/2013
/ Debt Securities ,
Dodd-Frank ,
Eligibility ,
Equity Securities ,
Exemptions ,
Offerings ,
Private Equity ,
Private Offerings ,
Regulation A ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Startups
The CFPB has ordered Mortgage Master, Inc. and Washington Federal to pay civil penalties for violating the Home Mortgage Disclosure Act, or HMDA, which requires certain mortgage lenders to accurately collect and report data...more
At this time, there are relatively few new items that need to be considered for the upcoming proxy and 10-K season. Those involved with the SEC reporting process may want to review our publication “A Lawyer’s Guide to...more
A law firm has submitted a rule making petition to the SEC to amend the rule governing the conflict minerals disclosure on Form SD to permit, for a temporary period, an alternative disclosure. The petition states “based upon...more
In Murray v. UBS Securities LLC et al (12-CV-5914 S.D.N.Y.) the court found that an employee who reports violations of securities laws to his supervisor, but not the SEC, is entitled to the anti-retaliation protections for...more
The CFTC has issued a final rule to exempt swaps between certain affiliated entities within a corporate group from the clearing requirement under the Commodity Exchange Act, or CEA, and CFTC regulations. ...more
Since the beginning of 2013, the CFTC has required certain market participants to report their interest rate and credit index swap trades to a swap data repository, or SDR. CFTC Commissioner Scott D. O’Malia recently...more