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Veil Parted on SEC Whistleblower Award

Early this year, the SEC announced it had paid a whistleblower award of “more than $700,000” to a company “outsider” who “conducted a detailed analysis” that led to a successful enforcement action against the company....more

FINRA to Assess Member Firms’ Culture

Speaking at the Brookings Institution this April, FINRA head Richard Ketchum emphasized the importance of a broker-dealer having a "culture" that favors the firm’s customers when their interests conflict with those of the...more

Junk Bond Fund Failure Challenges Industry

The December failure and ongoing liquidation of the Third Avenue Focused Credit Fund (TAFCF) provides potential ammunition to significant financial services industry players who believe mutual funds and investment managers...more

SEC Provides Long-Awaited Guidance on Fund Distribution and Sub-Accounting Fees

Guidance Update No. 2016-01, published this month by the SEC’s Division of Investment Management, provides extensive guidance concerning the possibility that payments from mutual funds are being used to promote sales of the...more

eCommerce Regulation, Bitcoin, Anti-Money Laundering, Shadow Insurance, 401(k) Litigation [Expect Focus – Vol. IV, Fall 2015]

IN THE SPOTLIGHT - - California Passes Life and Annuity Electronic Transactions Law LIFE INSURANCE - - Under a Spotlight, "Shadow Insurance" Lawsuit Fails Scrutiny - NAIC Evaluates Insurer’s Use of Variable...more

Feds Fish in Form PF

Annual reports that the SEC must submit to Congress provide insight into how the agency is exploiting the wealth of information that private fund advisers are required to file with it on Form PF. The SEC developed Form PF...more

SEC Reconsiders Exchange-Traded Products

The SEC recently published myriad questions about the listing, trading, and marketing (especially to retail investors) of "new, novel, or complex" exchange-traded products (ETPs). Such ETPs include exchange-traded funds...more

Global Regulators Evolve on Money Manager Systemic Risks

The Board of the International Organization of Securities Commissions (IOSCO) in June made an important recommendation concerning any risks that investment funds and advisors present to the global financial system....more

Trademarks in Cuba, Successful Whistleblowers, Big Data, Health Care Encryption, Jury Instruction Tips [Expect Focus – Vol. 1,...

IN THE SPOTLIGHT · Is your Company Ready to Comply with Encryption of Individually Identifiable Health Information? LIFE INSURANCE · STOLI Schemers Must Make Good on Damages Caused · At the State Level, Is a Fixed-Index...more

4/10/2015

FSOC Presses SEC on Money Managers’ Systemic Risks

The SEC is stepping lively to preserve a role in formulating any additional requirements for money managers—such as mutual funds and investment advisers—to limit perceived risks to the financial system. Although the...more

Expect Focus - Spot The Regulator, Volume IV, Fall 2014

In This Issue: - IN THE SPOTLIGHT ..Crisis Management: Five Steps to Take Before Providing That Comment - LIFE INSURANCE ..Third Circuit Limits ERISA Fiduciary Liability to those with Ultimate...more

Broker-Dealer Fee Disclosure Under Microscope

In September, state securities regulators formed a working group aiming to make broker-dealers’ disclosures about their fees more clear, accessible, and useful to investors in comparing different firms’ charges. The group...more

Guidance for Investment Advisers Using Proxy Advisory Firms

A recent SEC Staff Legal Bulletin provides important guidance for investment advisers that use proxy advisory firms in voting clients’ securities. Nevertheless, the Bulletin (dated June 30, 2014) leaves much unresolved....more

Expect Focus - Catching The Next Wave, Regulatory and Litigation Developments - Volume II, Spring 2014

In This Issue: - IN THE SPOTLIGHT ..Private Equity: The Next Wave of SEC Enforcement Actions? - LIFE INSURANCE ..How to Fight a STOLI Scheme: Court Rulings Offer Clues ..STOA Schemes Face...more

New FINRA Supervision Rules May Require Immediate Action

The SEC approved FINRA’s major reworking of its rules governing broker-dealers firms’ supervision of their offices and associated persons. Firms must comply with the new rules by December 1, 2014. This may require some firms...more

Mutual Funds Get Congressional Help Against FSOC

Some members of Congress have come to the aid of the investment management industry in its battle to avoid determinations by the Financial Stability Oversight Council (FSOC) that any mutual funds or investment advisers...more

More Due Diligence For Investments In Private Funds

The SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a January 28, 2014 Risk Alert summarizing current practices and trends in how investment advisers conduct due diligence on private funds they recommend...more

Rule 506: Too Cumbersome For Private Offerings?

The SEC has been pursuing several initiatives that, taken together, would significantly increase the difficulties and uncertainties presented by the securities registration exemption found in Rule 506 of Regulation D....more

Expect Focus - Volume 1, Winter 2014

In This Issue: - IN THE SPOTLIGHT ..Sixth Circuit Revisits Controversial ERISA Decision - LIFE INSURANCE ..Summary Judgment Victory for Life Insurer in Annuity Class Action ..Favorable Secondary Life Market...more

3/31/2014
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