News & Analysis as of

Disclosure Investment

Skadden, Arps, Slate, Meagher & Flom LLP

PISCES: Assessing Its Key Features and Potential Impact

On 14 November 2024, the UK government published a response to its consultation on creating a new regulated market to trade shares in private companies: the Private Intermittent Securities and Capital Exchange System...more

White & Case LLP

Side Letters: Just Paper Tigers, Or Do They Roar?

White & Case LLP on

Side letters document bespoke arrangements between all or certain parties to a financing transaction and supplement the terms of the principal documents thereto. Becoming increasingly popular with stakeholders, and with the...more

Skadden, Arps, Slate, Meagher & Flom LLP

FCA Preserves Key Tool for Activists in Listing Rules Reform

Activist shareholders had a busy 2023: The incidence of activist campaigns in Europe soared by almost 70% compared to 2022, according to data compiled by Skadden and Activistmonitor. As we described in a previous issue of The...more

Jones Day

SEC Chair Warns Against "AI Washing"

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As public companies increasingly discuss their artificial intelligence ("AI") capabilities, the U.S. Securities and Exchange Commission ("SEC") reminds us that it is closely watching these claims....more

UB Greensfelder LLP

CMS Announces New Federal Disclosure Requirements for Nursing Homes

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On February 28, 2022, the Biden-Harris administration announced initiatives designed to improve care and accountability at skilled nursing facilities (SNF). Since that announcement, the Centers for Medicare and Medicaid...more

Sheppard Mullin Richter & Hampton LLP

CMS Issues Proposed Rule Requiring Nursing Homes to Disclose Additional Ownership Information, Including Ties to Private Equity...

On February 15, 2023, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that would require nursing homes enrolled in Medicare and Medicaid to disclose new information about their ownership and...more

Proskauer - Blockchain and the Law

Fraud Claims Against Token Issuer Dismissed Based on Disclosures to Accredited Investor

The organizers of an initial coin offering (ICO) recently won dismissal of an investor’s fraud claims by establishing that their public risk disclosures negated the investor’s claims of reliance on alleged misstatements. The...more

McDermott Will & Emery

Pflicht zur ESG-Kundenbefragung gilt zukünftig auch für Finanzanlagenvermittler

Nun also auch die Finanzanlagenvermittler! Das Bundeswirtschaftsministerium hat am 11. November 2022 einen Referentenentwurf für eine „Verordnung zur Änderung der Gewerbeanzeige- und der Finanzanlagenvermittlungsverordnung“...more

Perkins Coie

New York Cannabis Co. Investor Suit Survives Motion To Dismiss

Perkins Coie on

The District Court for the Western District of New York denied a motion on January 6, 2023, to dismiss claims alleging that a publicly traded company misled investors regarding an investigation by the U.S. Securities and...more

Faegre Drinker Biddle & Reath LLP

Discretionary Management of IRAs: Conflicts and Prohibited Transactions

Both the Internal Revenue Code (Code) and the Employee Retirement Income Security Act of 1974 (ERISA) include prohibited transaction provisions that literally prohibit certain transactions (unless exempted by statute or by a...more

Fenwick & West LLP

Pump-and-Dumpers Take Their Lumps: Influencer Liability Catches the Eye of Federal Regulators

Fenwick & West LLP on

Influencers and their large and impressionable followings have become a valuable marketing tool for brands big and small. However, brands and influencers alike should proceed with caution as regulators continue to scrutinize...more

Foley Hoag LLP - White Collar Law &...

ESG Enforcement Actions Underscore SEC Focus on Public Company and Investment Adviser Disclosure

The formation of SEC Enforcement’s Climate and ESG Task Force last year confirmed that ESG had become one of the agency’s top enforcement priorities, and signaled that an uptick in investigations and enforcement actions...more

Sheppard Mullin Richter & Hampton LLP

SEC Announces 2022 Examination Priorities, Includes ESG

On March 30, 2022 the U.S. Securities and Exchange Commission (“SEC”) announced its 2022 examination priorities. Among the “significant focus areas” is Environmental, Social, and Governance (“ESG”) investing...more

Bass, Berry & Sims PLC

The Not So Green-Friendly Practice of Greenwashing

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As investors, advisers, corporations and other stakeholders become increasingly focused on environmental, social and governance (ESG) investments and disclosures, regulators are becoming increasingly concerned with potential...more

Katten Muchin Rosenman LLP

Securities Regulatory and Enforcement: Four Asset Management Trends

When the United States Investment Company Act and the Investment Advisers Act of 1940 came into force, assets under management were a mere $1 billion. Sixty years later they topped $20 trillion, and by the end of 2020, they...more

Sheppard Mullin Richter & Hampton LLP

Implications of SEC’s Scrutiny of Data Use Representations

The SEC’s enforcement action with a leading seller of market data (App Annie Inc.) signals its concern with misleading data use representations. While the data at issue was not “personally identifiable” information, but...more

Vinson & Elkins LLP

Scorecards Could Potentially Complicate How Corporations and Investors Address Environmental Justice

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Estimating, reporting, and mitigating risk concerning environmental justice (“EJ”) has increasingly become a complex undertaking. The EPA defines environmental justice as “the fair treatment and meaningful involvement of all...more

White & Case LLP

Q&A: The case for a market-wide approach to sustainable business practices

White & Case LLP on

Frederick Alexander, Chief Executive Officer and founder of the Shareholder Commons—a nonprofit organization focused on issues and structures for a sustainable, just economy— discusses how systemic changes can help companies...more

McDermott Will & Emery

Department of Labor Exemption Impacts Investment Advice Fiduciaries

McDermott Will & Emery on

The US Department of Labor (DOL) recently issued guidance concerning a new exemption under the prohibited transaction provisions of the Employee Retirement Income Security Act of 1974 (ERISA) in connection with the provision...more

Morrison & Foerster LLP

FCA And FRC Regulatory Intervention On Corporate Climate-Related Reporting

The financial services sector plays a vital role in the fight against climate change. It has long been recognised that regular and accurate disclosure of information on climate-related risks and opportunities can help...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #32

Regulation Best Interest: Best Interest and Suitability—How They Differ (Part 3) - Regulation Best Interest (Reg BI) imposes a “best interest” standard of care on broker-dealers for their recommendations of securities and...more

Orrick - Finance 20/20

European Commission Adopts Delegated Regulation on Presentation of Investment Recommendations and Disclosure of Conflict of...

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The European Commission has adopted a Delegated Regulation supplementing the Market Abuse Regulation (“MAR“) with regard to regulatory technical standards for the technical arrangements for the objective presentation of...more

K&L Gates LLP

SEC Enforcement Actions Against Investment Advisers

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According to the SEC’s most recent financial report, as of August 2014, SEC-registered investment advisers managed $62.3 trillion in assets. Not surprisingly, investment advisers attract a great deal of attention from the...more

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