SEC Charges Private Equity Adviser for Unregistered Brokerage Activity

by Dechert LLP

The U.S. Securities and Exchange Commission (SEC) on June 1, 2016 announced a settled enforcement action against a private equity fund manager (Adviser) for acting as a broker-dealer without registering.1 The case is significant because it calls into doubt certain compensation practices that became nearly universal among private equity firms following SEC staff guidance.2

According to the SEC, the Adviser received at least $1,877,000 in transaction-based compensation for providing brokerage services to the funds it managed and to the portfolio companies owned by the funds.3

Without admitting or denying the findings, the Adviser agreed to be censured, and one of its principals (Principal) agreed to cease and desist from further violations and, jointly and severally, to pay disgorgement of over $2.3 million, including over $500,000 to be distributed to affected clients. The Adviser also agreed to pay approximately $280,000 in interest and a $500,000 penalty.

SEC Focus on Unregistered Broker-Dealers and Implications for Private Equity Firms

Under the Securities Exchange Act of 1934 (Exchange Act), any person who engages in the business of acting as a broker or a dealer is required to register as a broker-dealer or as an associated person of a broker-dealer.4 For decades, the SEC has provided guidance in no-action letters as to when a person is considered to be “engaged in the [securities] business.”5 Guidance also can be found in SEC enforcement actions against market participants that the SEC has determined were acting as broker-dealers without benefit of registration.6

Private equity managers have historically charged both management fees (which are an expense of the funds) and transaction-related fees (which are charged to portfolio companies). Managers and their counsel have been aware of the SEC staff’s concerns about receiving transaction-based fees when the manager is not registered as a broker-dealer. Offsetting transaction fees against private equity fund management fees has been seen as a method for passing the benefit of the fees to the relevant fund’s limited partners, and most private equity managers have increased such offsets in recent years.

In 2013, the then-Chief Counsel of the SEC’s Division of Trading and Markets, in a widely noted speech to the American Bar Association’s Trading and Markets Subcommittee, said that “absent an available exemption or other relief, a person engaged in the business of effecting transactions in securities for the account of others must generally register under Section 15(a) of the Exchange Act as a broker.”7 Much of the rest of the then-Chief Counsel’s remarks focused on the SEC staff’s long-standing view that engaging in certain activities and receiving transaction-based or success-based fees for such activities would trigger the registration requirements of the Exchange Act – all well-known and uncontroversial positions. The former Trading and Markets' Chief Counsel also noted certain practices that private equity managers had adopted that appeared to ameliorate the broker-dealer registration concerns, stating that “to the extent the advisory fee is wholly reduced or offset by the amount of the transaction fee, one might view the fee as another way to pay the advisory fee, which, in my view, in itself would not appear to raise broker-dealer registration concerns.” This remark was the genesis of the widely held view – called into question at the beginning of June – that a 100% offset of portfolio transaction fees would not trigger broker-dealer registration for a private equity manager. Offsets of less than 100%, widely used in funds offered prior to the 2013 speech, have been disappearing from more recently formed funds, accelerating a trend that was already promoted by investor demand. Since 2013, and particularly in light of changes in senior staff of the SEC’s Division of Trading and Markets, many in the private equity community hoped for and have sought additional formal or informal guidance that would solidify this view of the relationship between private equity transaction fees and the broker-dealer registration requirements.

Although the SEC staff has not issued private equity-specific guidance, on January 31, 2014, the staff issued a no-action letter providing guidance on avoiding broker-dealer registration for a distinct category of brokers engaged in securities transactions of privately-held companies (M&A Brokers).8 While a move in the right direction for the private equity community, many of the conditions to qualify as an M&A Broker conflict with the roles typically performed by private equity sponsors during the purchase or sale of private portfolio companies, including restrictions on control and custody of the related securities and involvement in financing arrangements.9 Nevertheless, the then-Chief Counsel’s remarks and the M&A Broker no-action letter fostered a growing acceptance of certain activity by persons who were not registered as broker-dealers, even though the activities had been at other times characterized by the SEC staff as badges of broker-dealer status. This latest SEC action threatens to undo that evolution.

Without mentioning whether the Adviser’s funds benefitted from offsets, the specific facts of the transaction fees earned by the Adviser, or whether the Adviser qualified as an M&A Broker, the SEC determined that the Adviser and its Principal were engaged in brokerage services “with respect to the acquisition and disposition of portfolio companies, some of which involved the purchase or sale of securities, […] including soliciting deals, identifying buyers or sellers, negotiating and structuring transactions, arranging financing, and executing the transactions.” As the SEC’s Order indicated, disclosure was not the issue, as the fund documents permitted the Adviser to charge transaction or brokerage fees.10 Rather, the SEC charged that the Adviser and its Principal were not properly registered, or otherwise exempt from registration, as a broker-dealer. The SEC did not discuss the issue of offsets in its Order, which raises concerns about whether the use of offsets avoids broker-dealer registration requirements. This confusion is exacerbated because the Order was issued by the SEC, while the prior guidance came from the SEC staff.

Additional Violations

The SEC also faulted the Adviser for a number of additional issues. First, the Adviser was found to have failed to disclose, until after investors had committed capital, the payment of (and conflicts associated with) certain operating partner oversight fees paid by fund portfolio companies to the Adviser, where the Adviser’s personnel provided the portfolio companies certain “senior-level operating and management services to these companies in circumstances where the companies were having difficulty recruiting suitable talent to work directly for them.” The SEC also noted that these fees were not addressed in at least one of the fund’s governing documents.

Second, the SEC stated that the Adviser charged its funds for certain political and charitable contributions and entertainment expenses, including a luxury suite in Washington DC’s Verizon Center, even though such charges were not disclosed “until after the LPs committed capital and until after the contributions were made and the expenses occurred.”

Third, the SEC indicated that the Adviser engaged in an improper conflicted transaction when it purchased shares of its fund’s portfolio companies without proper disclosure to investors and in violation of a priority repurchase right held by such portfolio companies.

Fourth, the SEC indicated that the Principal violated the terms of a fund’s partnership agreement by purchasing interests of defaulting investors for his personal benefit rather than the fund, and by causing the fund to waive capital call obligations with respect to such interests (and additional interests he purchased) without proper disclosure to investors.

And fifth, the Adviser was charged with a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act of 1940, as amended, and its rules, including those list above.

Recent and Related Developments

On December 4, 2015, Financial Industry Regulatory Authority (FINRA) filed with the SEC a proposed rule change to create a new streamlined rule set (Proposed CAB Rules) that would apply to “Capital Acquisition Brokers” (CABs) and reduce their regulatory burden and compliance cost. This proposal may ease some of the burdens on private equity managers that do register as broker-dealers.

Unlike the M&A Broker no-action letter, CABs will have to register as broker-dealers and become FINRA members. Nevertheless, FINRA’s Proposed CAB Rules provide less onerous FINRA compliance obligations if the registered broker-dealer limits its activities to corporate financing services, such as advising companies on mergers and acquisitions, raising debt or equity capital in private placements with institutional investors, or helping companies analyze their strategic and financial alternatives. In many cases, these firms register as broker-dealers only because they receive transaction-based compensation. CABs would not be allowed to handle customer funds or securities, accept orders to purchase or sell securities, exercise investment discretion on behalf of customers, or engage in market making or proprietary trading. As of June 14, 2016, SEC approval of the Proposed CAB Rules is still pending.

Practical Effect of Order Remains Uncertain

The issue of unregistered brokerage activities by private equity fund advisers has been raised in the context of examinations and other inquiries to unregistered entities. In many cases, private equity fund advisers have been able to respond to the SEC staff’s questions without enforcement action being taken. In light of this latest action, it remains to be seen whether there has been a shift in the SEC’s or its staff’s position, which could lead to wholesale revamping of private equity fund fee structures or result in the registration of fund advisers as broker-dealers. Private equity fund advisers may wish to review their fee structures and other activities in light of the SEC’s recent action.


1) In the Matter of Blackstreet Capital Management, LLC and Murry N. Gunty, Rel. Nos. 34-77959 and IA-4411 (June 1, 2016). See also SEC: Private Equity Fund Adviser Acted As Unregistered Broker.

2) Lim, Dawn and Cumming, Chris, SEC Official Puts Broker-Dealer Issue Back on Private Equity’s Radar, The Wall Street Journal (June 7, 2016).

3) The SEC also found that the Adviser: (i) received undisclosed portfolio company oversight fees; (ii) used client assets for political/charitable contributions and entertainment expenses without authorization; (iii) purchased portfolio company interests without authorization; (iv) improperly purchased fund interests and exercised waivers for future funding obligations; and (v) failed to adopt and implement reasonably designed compliance policies and procedures. See Additional Violations, below.

4) See Section 15(a) of the Exchange Act.

5) See, e.g., Inland Realty Inv., Inc., SEC No-Action Letter (May 20, 1973), in which the SEC staff indicated that a person would be considered “engaged in the [securities] business” if the person receives transaction-based compensation in connection with securities transactions (the earning of a commission demonstrates success in effecting transactions for the account of others). See also MuniAuction, Inc., SEC No-Action Letter (Mar. 13, 2000), in which the SEC staff denied no-action relief from the broker-dealer registration requirements where the requestor conducted auctions of municipal bonds and other securities primarily on behalf of municipal bond issuers who wished to negotiate purchases and sales and used the MuniAuction website to communicate bids and accept offers. See also Davenport Management, Inc., SEC No-Action Letter (Apr. 13, 1993), in which the SEC refused to grant no-action relief to a corporation controlled by principals of a partnership that contracted with the corporation to, among other things, act as a “finder” for investors in, and investments for, the partnership, in exchange for transaction fees.

6) See Ram Capital Resources, LLC, Exchange Act Release No. 60149 (June 19, 2009), in which the SEC fined Ram Capital for selling PIPE investments without being registered as a broker-dealer and forced it to disgorge the fees it had earned. See also Ambit Capital Private Limited, Exchange Act Release No. 68295 (Nov. 27, 2012); Edelweiss Financial Services Limited, Exchange Act Release No. 68298 (Nov. 27, 2012); JM Financial Institutional Securities Private Limited, Exchange Act Release No. 68297 (Nov. 27, 2012); Motilal Oswal Securities Limited, Exchange Act Release No. 68296 (Nov. 27, 2012); and BANCO ESPIRITO SANTO S.A., Exchange Act Release No. 65608 (Oct. 24, 2011). In the foregoing actions, the SEC fined several Indian broker-dealers and a Portuguese bank for selling securities to U.S. investors without being registered. See also Ranieri Partners LLC and Donald W. Phillips, Exchange Act Release No. 69091 (Mar. 8, 2013). In Ranieri, the SEC fined Ranieri Partners, a principal of Ranieri and an independent contractor who was not registered, for selling investments in hedge funds it managed. State regulators in several states have recently shown more interest in pursuing unregistered broker-dealers for sales activities occurring in their states as well.

7) A Few Observations in the Private Fund Space, David W. Blass, Chief Counsel, Division of Trading and Markets, SEC, before the American Bar Association, Trading and Markets Subcommittee, Washington, D.C., April 5, 2013. As part of his remarks, Mr. Blass gave the standard SEC staff disclaimer that “my remarks represent my own views, and not those of the Commission, any individual Commissioner, or any other members of the staff.”

8) M&A Brokers, SEC No-Action Letter (January 31, 2014, as revised on February 4, 2014). Because only a limited number of states have adopted parallel exemptions, some market participants have concerns about the utility of the relief granted.

9) Id.

10) A takeaway from this decision is to ensure that documentation does not label or refer to services and compensation that would trigger the broker-dealer registration requirements, unless the facts otherwise require it.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Dechert LLP | Attorney Advertising

Written by:

Dechert LLP

Dechert LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.