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Enforcement Actions Securities and Exchange Commission (SEC) Reporting Requirements

Katten Muchin Rosenman LLP

SEC Reporting Parties Can Continue Following CFTC Reporting Rules When Reporting Security-Based Swap Data Until 2029

As a result of the Securities and Exchange Commission (SEC or the Commission) recently extending relief that the Commission originally granted under its 2019 Compliance Statement, security-based swap (SBS) market participants...more

Cooley LLP

Capital Markets Update – March 2025 One-Minute Reads

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New C&DIs related to Reg A and Reg D - On March 12, the Securities and Exchange Commission (SEC) Division of Corporation Finance (Corp Fin) issued new and updated compliance and disclosure interpretations (C&DIs) under...more

DarrowEverett LLP

Private Placements in South Carolina: A Primer on Federal and State Securities Registration

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With an estimated 34 people moving to the Charleston area each day and with South Carolina claiming one of the fastest-growing populations in the nation last year , the post-COVID increase in the number of private placement...more

Morris, Manning & Martin, LLP

"Custody" for Registered Investment Advisers in Unusual Circumstances

For most registered investment advisers (RIAs), their annual update to Form ADV will be due on March 31, 2025. We have received several questions about “custody” and peculiar situations where RIAs may inadvertently have...more

DLA Piper

SEC Permits Rule 506(c) Accredited Investor Verification with Self-Certification

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The US Securities and Exchange Commission (SEC) has published no-action guidance providing clarity to issuers relying on Rule 506(c) of Regulation D – an exempt offering pathway that permits issuers to publicly advertise an...more

Katten Muchin Rosenman LLP

Financial Markets and Funds Quick Take | Issue 36

Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds....more

Mayer Brown Free Writings + Perspectives

Lawmakers Ask SEC Acting Chair Uyeda to Review Approach to Consolidated Audit Trail

On February 28, 2025, House Financial Services Committee Chairman French Hill (R-AR), Senate Banking Committee Chairman Tim Scott (R-SC), and Senator Tom Cotton (R-AR) sent a letter (the “Letter”) to Securities and Exchange...more

Wilson Sonsini Goodrich & Rosati

Preparing for the 2025 Reporting Season: Proxy Season Reminders

With the 2025 proxy season upon us, this Alert highlights governance, disclosure, and engagement considerations for companies preparing for their 2025 annual meetings. Many of the governance and disclosure matters discussed...more

Katten Muchin Rosenman LLP

Privacy, Data and Cybersecurity Quick Clicks | Issue 26

Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe....more

Cooley LLP

Public Companies Update – February 2025 One-Minute Reads

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ISS issues statement regarding consideration of diversity factors in US director election assessments - Institutional Shareholder Services (ISS) announced that due to the recent increased attention on diversity, equity and...more

Mintz - Energy & Sustainability Viewpoints

A Quantitative Analysis of Comment Letters Issued by the SEC Concerning Climate Change Disclosures: Further Developments

In June 2023, Mintz published an article entitled “A Quantitative Analysis of Comment Letters Issued by the SEC Concerning Climate Change Disclosures” (the June 2023 Article), which analyzed the comment letters related to...more

Bressler, Amery & Ross, P.C.

Form D-elay: Shift in Enforcement?

Securities issuers and their counsel have historically relied on the fact that the SEC has not pursued enforcement actions against issuers that have not filed, or been delayed in filing, a Form D in connection with offerings...more

Fenwick & West LLP

Securities Law Update - February 2025

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Welcome to the latest edition of Fenwick’s Securities Law Update. This issue contains updates and important reminders on...more

Proskauer - Regulatory & Compliance

SEC Extends Compliance Date for Short Sale Reporting Rule to 2026

On February 6, 2025, the SEC announced that it was providing a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act of 1934 (the “Exchange Act”), which establishes a mandatory short reporting...more

Mayer Brown Free Writings + Perspectives

ICI Urges SEC to Delay Short-Sell Reporting Rules Amid Compliance Uncertainty

The Investment Company Institute (ICI) has asked the Securities and Exchange Commission (SEC) in a comment letter to delay enforcement of its new short sale disclosure rules (the “Short Sale Final Rules”) until additional...more

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Morgan Lewis

Current Developments in SEC Enforcement for Public Companies and a Look Ahead 2024–2025

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The US Securities and Exchange Commission (SEC) brought a number of notable enforcement proceedings against public companies in fiscal year 2024, which ended September 30, 2024, and into the first quarter of fiscal year 2025....more

Cooley LLP

SEC Commissioner Hester Peirce Provides Some Tea Leaves

Cooley LLP on

Normally, I don’t pay too much attention to the speeches that SEC Commissioners deliver because it’s the SEC Chair that wields the real clout. But given where we are with a new SEC Chair to be sworn in over the coming months...more

Ropes & Gray LLP

AI-Washing Enforcement in the Final Days of the Gensler Administration

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As former Securities and Exchange Commission (“SEC”) Chair Gary Gensler’s term came to a close following his resignation announcement in November 2024, the SEC issued another order targeting what has proved to be one of...more

Cadwalader, Wickersham & Taft LLP

SEC Brings Suit Against Elon Musk for Failure to Report Twitter Ownership

On January 14, 2025, the U.S. Securities and Exchange Commission (the “SEC”) sued Elon Musk over his 2022 acquisition of Twitter, Inc. stock and alleged failure to timely disclose a 5% ownership stake in Twitter, as required...more

Ropes & Gray LLP

Capital Markets & Governance Insights - January 2025

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Companies should not minimize the extent of a material cybersecurity incident by omitting material facts regarding the scope and potential impact of the incident. Cybersecurity risk factor disclosures should be tailored to a...more

WilmerHale

Keeping Up with the Regulators: How to Build an Effective Compliance Programme to Satisfy the Best Interest Care Obligation

WilmerHale on

It has been nearly five years since the US Securities and Exchange Commission (‘SEC’ or ‘the Commission’) adopted Regulation Best Interest (Reg BI) to enhance the standard of conduct applicable to broker-dealers when they...more

DLA Piper

Blockchain and Digital Assets News and Trends – January 2025

DLA Piper on

This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

Morgan Lewis - As Prescribed

Clinicaltrials.gov: Recent Action May Signal Increased Attention from FDA on Trial Data Reporting Compliance

The US Food and Drug Administration (FDA) recently issued a notice of noncompliance to the FADOI Foundation, citing the organization’s failure to submit required clinical trial results to ClinicalTrials.gov. The notice...more

Stinson - Corporate & Securities Law Blog

SEC Settles Charges Against Shift4 After Failing to Disclose Related-Person Transactions

In a settled enforcement action, the Securities and Exchange Commission (“SEC”) charged Shift4 Payments, Inc. (“Shift4”), a payment processing company based in Pennsylvania, with failing to disclose payments made to immediate...more

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