News & Analysis as of

No-Action Letters Policies and Procedures

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - September 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Ballard Spahr LLP

CFPB addresses RESPA issue in its first no-action letter under the revised final policy

Ballard Spahr LLP on

In its first No-Action Letter under the new revised policy, the CFPB addresses a long-standing issue under the Real Estate Settlement Procedures Act regarding certain payment arrangements between mortgage lenders and housing...more

Faegre Drinker Biddle & Reath LLP

SEC Adopts Final Auditor Independence Loan Rule

On June 18, 2019, the Securities and Exchange Commission (“SEC”) adopted final amendments to Rule 2-01(c)(1)(ii)(A) of Regulation S-X (the “Loan Rule”) to clarify the analysis that must be conducted to determine whether an...more

Robins Kaplan LLP

ESG Investor Walden Scores Win on CorVel Shareholder Proposal Re LGBTQ Rights

Robins Kaplan LLP on

On June 5, 2019, the Securities and Exchange Commission (SEC) declined to issue a no-action letter to CorVel Corporation with respect to CorVel’s intention to exclude from its proxy materials a shareholder proposal regarding...more

Dechert LLP

SEC Staff Withdraws Guidance on Proxy Firms and Holds Proxy Roundtable; Chairman Clayton Indicates that SEC Will Act in 2019

Dechert LLP on

In connection with the public roundtable on the proxy voting process (Roundtable) held by the staff of the Securities and Exchange Commission on November 15, 2018, the staff of the SEC’s Division of Investment Management (IM...more

A&O Shearman

SEC Staff Eases Fund Director Burdens

A&O Shearman on

For decades, mutual fund directors have turned to quarterly reports on affiliated cross trades, participation in affiliated underwritings and affiliated brokerage; the reports themselves state that the trades are in...more

Morrison & Foerster LLP

CFPB Publishes No-Action Letter Policy Statement

On February 22, 2016, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) published its Final Policy Statement (“Final Policy”) on No-Action Letters (“NALs”). The Final Policy follows a Proposed Policy on...more

Mintz

Citizen.VC No Action Letter: Clarity and Guidance for Conducting a Private Placement Online

Mintz on

The SEC has recently provided clarity as to how an issuer of securities can conduct a private placement in a password protected web page under Rule 506(b), without it being deemed a “general solicitation” and thereby being...more

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