Machine Learning for Environments with Bad Actors
Jenny Radcliffe on People Hacking
AFSA Extra Credit Podcast: Navigating Advertising During COVID-19
Compliance Perspectives: The Right Kind of Wrong
JOBS Act Implementation Regulations
On September 12, the U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler testified before the U.S. Senate Committee on Banking, Housing, and Urban Affairs. His testimony emphasized that market growth combined...more
In this issue, we summarize regulatory, litigation and industry developments from May to September 2019 impacting the investment management sector, including SEC action on standards of conduct for broker-dealers and...more
The Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as...more
Companies seeking to expand operations often face numerous challenges. One such challenge is raising the capital necessary to make such an expansion possible. When a company sees an expansion opportunity but does not have the...more
The SEC has consistently demonstrated concern over the marketing of cryptocurrency trading and investments in initial coin offerings (“ICOs”), which SEC Chairman Jay Clayton has called “fertile ground for bad actors to take...more
When looking to raise capital, broker-dealer compliance may not be at the forefront of a private fund manager’s mind. However, engaging individuals (including the fund manager’s employees) or firms to identify, introduce or...more
Introduction - Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals. ...more
Investment Advisers - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their compliance...more
The SEC has been thinking harder before waiving automatic disqualifications that the federal securities laws and regulations impose on so-called "bad actors." Without such waivers, companies may be barred from, among...more
One key debate regarding current SEC enforcement policy centers on the application of the so-called “bad actor” provisions. Previously the Commissioners split over the nature, use and application of those provisions. ...more
- Regulatory Updates: CFTC Adopts “Substituted Compliance” Approach for Registered Investment Companies that are Commodity Pools; SEC’s Final Rules on General Solicitation and Bad Actor Disqualification for Investment...more
The SEC recently finalized amendments to Rule 506 of Regulation D and Rule 144A under the Securities Act relaxing prohibitions against general solicitation in certain private offerings of securities implementing Section...more