On February 5, 2025, Robert Cook, President and Chief Executive Officer of the Financial Industry Regulatory Industry, Inc. (“FINRA”), announced that FINRA will not set an effective date for its recent amendments (the...more
On February 7, 2025, the US Securities and Exchange Commission (SEC) provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and the associated Form SHO reporting. Originally, the...more
The Securities and Exchange Commission (SEC) staff issued updated FAQs regarding Rule 35d-1 under the Investment Company Act of 1940 (the “Names Rule”) on January 8, 2025. These updates reflect amendments that were adopted...more
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
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have extended the compliance deadline for the amendments to Form PF, moving it from March 12, 2025 to June 12, 2025....more
The Securities and Exchange Commission’s (SEC) Small Business Capital Formation Advisory Committee will meet on February 25, 2025 to discuss capital-raising challenges for emerging fund managers and smaller public companies...more
According to CB Insights’ State of Fintech 2024 Report (the “Report”), global fintech companies raised $33.7 billion in private placements in 2024, marking a 20% drop year-over-year. Deal volume also declined, with 3,580...more
The Securities and Exchange Commission (SEC) announced that Mark T. Uyeda has been appointed Acting Chair. The Acting Chair has served as an SEC Commissioner since June 2022 and brings extensive experience to the role,...more
This Legal Update summarizes the US Securities and Exchange Commission’s 2025 calendar year filing deadlines and financial statement staleness dates....more
Here’s the deal:
• A Rule 10b5‐1 plan is a written securities trading plan that is designed to comply with Rule 10b5‐1(c) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”)....more
1/15/2025
/ 10b5-1 Plans ,
Compliance ,
Corporate Governance ,
Disclosure Requirements ,
Insider Trading ,
Investors ,
MNPI ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Regulation
Here’s the deal:
A Rule 10b5‐1 plan is a written securities trading plan that is designed to comply with Rule 10b5‐1(c) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”)....more
1/7/2025
/ 10b5-1 Plans ,
Capital Markets ,
Compliance ,
Corporate Governance ,
Insider Trading ,
MNPI ,
Publicly-Traded Companies ,
Regulation S-K ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Securities Regulation
On December 31, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24-18 (“RN 24-18”) to provide updated guidance to members regarding Rules 15c3-1, 15c3-3 and 17a-5 under the...more
On December 16, 2024, the Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) requiring the electronic filing, submission, or posting of certain forms required under the Securities Exchange Act of...more
As discussed in our prior post, the Securities and Exchange Commission’s Office of the Advocate for Small Business Capital Formation recently issued its 2024 Annual Report....more
The Securities and Exchange Commission’s Investor Advisory Committee (the “Committee”) will meet on Tuesday, December 10, 2024, in an open meeting, that will stream on the SEC’s website. The Committee will first hear from...more
Broker-dealers had been preparing for the sunset of the prior time-based relief that the staff of the Securities and Exchange Commission provided in respect of compliance with Rule 15c2-11 as to certain fixed income...more
At the Practising Law Institute’s 56th Annual Institute on Securities Regulation, panelists discussed how public companies are addressing cybersecurity and artificial intelligence (AI) related issues....more
11/19/2024
/ Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Cyber Threats ,
Cybersecurity ,
Disclosure Requirements ,
NIST ,
Risk Factors ,
Risk Management ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On November 14, 2024, the Practising Law Institute’s 56th Annual Institute on Securities Regulation featured a panel discussion that provided valuable insights into the initial public offering (IPO) landscape for 2025....more
On October 21, 2024, the Division of Examinations (“EXAMS” or the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) released its examination priorities (the “2025 Priorities”) for fiscal year 2025 (which...more
In September 2024, the Securities and Exchange Commission charged a consumer products company (the “Company”) with having made inaccurate claims regarding the recyclability of its single-use coffee pods. The SEC found that...more
A broker-dealer failed to reasonably supervise its registered representatives when making recommendations of certain variable rate structured products (“VRSPs”), including fixed to floating rate steepeners and other variable...more
The Chair and Commissioners of the Securities and Exchange Commission testified before the US House of Representatives Committee on Financial Services on September 24, 2024. The SEC’s testimony provided updates on market...more
10/8/2024
/ Beneficial Owner ,
Capital Markets ,
Climate Change ,
Cybersecurity ,
Environmental Social & Governance (ESG) ,
Investment Management ,
Investors ,
Registered Investment Advisors ,
Reporting Requirements ,
Risk Management ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Special Purpose Acquisition Companies (SPACs)
The SEC recently published its report on the 2024 Government-Business Forum on Small Business Capital Formation. The Forum addresses a range of issues affecting small businesses, including smaller public companies. The...more
A broker-dealer (the “Dealer”) entered into a cease-and-desist order with the Securities and Exchange Commission for failing to maintain and enforce written policies and procedures reasonably designed to achieve compliance...more
The Securities and Exchange Commission recently announced that it will host a compliance outreach program on November 7, 2024 (see the program’s agenda) on Advisers Act and Investment Company Act related topics. The agenda...more