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Preemption Securities and Exchange Commission (SEC)

BCLP

SEC Enforcement Actions for Failure to File Form D: A Wake-up Call for Startups and Private Fund Advisers

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On December 20, 2024, the U.S. Securities and Exchange Commission (the “SEC”) issued a press release highlighting settled enforcement actions against a private fund adviser and two pre-IPO companies for failure to timely file...more

Dorsey & Whitney LLP

The Supreme Court Update - June 27, 2024

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The Supreme Court of the United States issued four decisions today: Moyle v. United States; Idaho v. United States, Nos. 23-726, 23-727: After granting certioriari to decide whether the Emergency Medical Treatment and...more

BCLP

Call for Vacatur of Massachusetts’ Fiduciary Duty Standard for Broker/Dealers

BCLP on

On August 25, 2023, Justice Wendlandt of the Massachusetts Supreme Judicial Court issued a ruling in Robinhood Financial, LLC v. Secretary of the Commonwealth which upheld the legality of the fiduciary duty standard imposed...more

Goodwin

FinCEN Issues Initial Beneficial Ownership Information Reporting Guidance

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Regulatory Developments - FinCEN Issues Initial Beneficial Ownership Information Reporting Guidance - On March 24, FinCEN published guidance materials for the new beneficial ownership reporting requirements taking...more

Mayer Brown Free Writings + Perspectives

A New Federal Exemption from Broker Registration for Qualifying M&A Brokers Became Effective on March 29, 2023 (Prior SEC...

Although the New Federal Exemption Is Generally Aligned with the SEC’s 2014 No-Action Relief, There Are Some Notable Differences. Moreover, State Law Registration Requirements for M&A Brokers Are Not Preempted. ...more

BakerHostetler

New DOJ Policies Tie Employee Compensation to Compliance

BakerHostetler on

On March 15, 2023, the U.S. Department of Justice (DOJ or the Department) launched a three-year Compensation Incentives and Clawbacks Pilot Program (Clawback Program) intended to incentivize companies to create more robust...more

Morrison & Foerster LLP - Left Coast Appeals

This Week at the Ninth: Short Swings and Medicare Advantage

This week, the Ninth Circuit addresses short-swing transactions involving board-approved stock option grants and considers the preemptive scope of the Medicare Act. ...more

Proskauer Rose LLP

10 Developments That Shaped Employment Law In 2021

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2021 was a transformative year for labor and employment law and fundamental employment dynamics. There was no shortage of highly influential decisions issued by courts around the country in 2021 — and California continues to...more

Allen Matkins

Claw Backs And Preemption

Allen Matkins on

Last week, the Securities and Exchange Commission announced that it was reopening the comment period on proposed rules for listing standards for the recovery of erroneously awarded compensation...more

Winstead PC

SEC Investment Advisers: Texas says “April Fools!” to Federal Preemption?

Winstead PC on

On April 1, 2021, the Texas State Securities Board (TSSB) announced the entry of a Consent Order against an SEC registered investment adviser named Independent Financial Group, LLC (“Independent”). The TSSB’s action may...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

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In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2020

Federal Regulators Ease Restrictions on Volcker Rule Covered Funds  The federal banking agencies, along with the SEC and the CFTC, have issued a final rule to amend the regulations that implement Section 13 of the Bank...more

Allen Matkins

Is A Pre-Issuance Form D Filing Requirement In The Offing?

Allen Matkins on

The North American Securities Administrators Association (NASAA) is a century old organization that represents state and provincial securities regulators in Canada, Mexico and the United States. Although the states were first...more

Skadden, Arps, Slate, Meagher & Flom LLP

D.C. Circuit Upholds Federal Pay-to-Play Rule

On June 18, 2019, the U.S. Court of Appeals for the District of Columbia Circuit (the court) dismissed a challenge to Financial Industry Regulatory Authority (FINRA) pay-to-play Rule 2030 (the rule) brought by the New York...more

Allen Matkins

SEC Passes Preemption Question To The Courts

Allen Matkins on

Yesterday, the Securities and Exchange Commission approved Regulation Best Interest. According to the SEC's announcement, this new regulation will require brokers "to act in the best interest of a retail customer when making...more

Eversheds Sutherland (US) LLP

Preemption of state securities laws

With the recent announcement by the Securities and Exchange Commission (SEC) that it will hold an open meeting on June 5, 2019, to consider adopting Regulation Best Interest, one of the major issues that the SEC may clarify...more

Allen Matkins

Will Regulation "Best Interest" Preempt State Law?

Allen Matkins on

Yesterday's post concerned possible arguments that federal law preempts Nevada's fiduciary standard for broker-dealers. At present, any preemption would have to be based on the National Securities Markets Improvement Act...more

Ballard Spahr LLP

SEC consumer advocates launch misguided preemptive attack on arbitration clauses

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Having lost the battle to prohibit class action waivers in consumer arbitration agreements, consumer advocates have embarked on a new crusade....more

Ballard Spahr LLP

SEC Consumer Advocates Launch Misguided Preemptive Attack on Arbitration Clauses

Ballard Spahr LLP on

Having lost the battle to prohibit class action waivers in consumer arbitration agreements, consumer advocates have embarked on a new crusade....more

Carlton Fields

Expect Focus - Volume II, June 2018

Carlton Fields on

New York Pushes Mutual Fund Active Share Disclosure - New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as “Active Share.”...more

Dorsey & Whitney LLP

New Law Allows for Regulation A+ Offerings by Reporting Companies

Dorsey & Whitney LLP on

On May 24, the Economic Growth, Regulatory Relief, and Consumer Protection Act (the “Act”) was signed into law. One of the purposes of the Act is to encourage capital formation by directing the Securities and Exchange...more

Stinson - Corporate & Securities Law Blog

Dodd-Frank Rollback Requires Changes to Regulation A+ and Rule 701

The Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155), which is primarily aimed at easing regulations on community banks, also contains provisions designed to facilitate capital formation. President...more

Allen Matkins

Will "Best Interest" Preempt Fiduciary Duties?

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Last month, the Securities and Exchange Commission proposed to established a standard of conduct for broker-dealers when making a recommendation of any securities transaction or investment strategy involving securities to a...more

Allen Matkins

California Lags Behind The SEC In Permitting Testing Of The Waters In Regulation A Offerings

Allen Matkins on

In 2015, the Securities and Exchange Commission adopted amendments to Regulation A and other rules and forms to implement Section 401 of the Jumpstart Our Business Startups (JOBS) Act. One significant enhancement to...more

Allen Matkins

Magistrate Judge Rules SEC’s Attorney-Conduct Rules Preempt State Law

Allen Matkins on

Last December, Chief Magistrate Judge Joseph C. Spero ruled that the SEC’s attorney-conduct rules preempt California’s statutory and professional rules requiring attorneys to maintain inviolate the confidences. Wadler v....more

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