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SEC’s Proposed Changes to “Accredited Investor” and “Qualified Institutional Buyer” Definitions

On Dec. 18, 2019, the Securities and Exchange Commission (SEC) proposed changes to the definition of “accredited investor” under Regulation D to broaden the definition and identify more effectively the pool of investors that...more

SEC Filing Fee Rate Increase Effective Oct. 1, 2019

In its first fee rate advisory for fiscal year 2020, the SEC announced that filing fees applicable to securities registrations by public companies and other issuers will be increased by 7.1%: from $121.20 to $129.80 per...more

SEC Division of Corporate Finances Issues 9 Compliance and Disclosure Interpretations Regarding Inline XBRL Requirements

In March 2019, final rules amending Regulation S-K and related rules and forms were adopted. Included in these rules were requirements that registrants use Inline XBRL, a machine-readable computer code, to tag certain...more

SEC Brings Enforcement Action against TherapeuticsMD for Violations of Regulation FD

On Aug. 20, 2019, the Securities and Exchange Commission (SEC) announced that it had charged public pharmaceutical company TherapeuticsMD, Inc. for violations of Regulation FD and Section 13(a) of the Exchange Act related to...more

SEC Proposes to Modernize Disclosures of Business, Legal Proceedings and Risk Factors Under Regulation S-K

As reported in a press release issued by the Securities and Exchange Comission (the SEC) on Aug. 8, 2019, the SEC voted to propose amendments to modernize Regulation S-K disclosures, in particular, Item 101(a) (the...more

SEC Issues Statement on LIBOR Transition

On July 12, the staffs of the Division of Corporation Finance, Division of Investment Management, Division of Trading and Markets, and Office of the Chief Accountant (the “Staffs”) of the Securities and Exchange Commission...more

How the SEC’s Proposed Amendments to Financial Disclosures for Acquisitions Will Affect High-Yield Bond Offerings

On May 3, the Securities and Exchange Commission (the SEC) proposed amendments to its rules governing financial disclosures relating to acquisitions and dispositions of businesses....more

SEC Settlement in the Curt Schilling 38 Studios Matter Highlights the Section 17(a)(2) Liability of Initial Purchasers in Rule...

On March 20, 2019, an agreement between Wells Fargo Securities LLC (Wells Fargo) and the Securities and Exchange Commission (SEC) to settle litigation involving failed video game company 38 Studios, LLC, headed by former...more

SEC Adopts Amendments to Implement Fast Act Disclosure Modernization and Simplification

On March 20, 2019, the Securities and Exchange Commission (the SEC) voted to adopt amendments to modernize and simplify disclosure requirements for public companies, investment advisers and investment companies. ...more

SEC Proposes to Expand "Test the Waters" to All Issuers

Background On Feb. 19, 2019, the Securities and Exchange Commission (the SEC) voted to propose a rule and related rule amendments under the Securities Act of 1933, as amended (the Securities Act)...more

SEC Takes Its Initial Aim at Crypto Funds

In a regulatory first, the Securities and Exchange Commission (SEC) has issued a cease and desist order and imposed a $200,000 fine against a hedge fund that invested in digital assets and its founder. ...more

SEC Amends Definition of ‘Smaller Reporting Company’ Expanding the Number of Companies Eligible for Reduced Disclosure

On June 28, 2018, the Securities and Exchange Commission voted to amend the definition of “smaller reporting company” (SRC) to expand the number of companies eligible to take advantage of the reduced disclosure requirements...more

SEC Approves NYSE Rule Changes on Listing Without an IPO

The Securities and Exchange Commission (SEC) has approved a proposal by the New York Stock Exchange (NYSE) to facilitate listing on the NYSE without a prior underwritten public offering. Section 102.01B of the NYSE Listed...more

Funds Talk: February 2018

Global Regulators Increasingly Shifting Focus to Cryptocurrency - After years of allowing cryptocurrency transactions to fly under the radar, financial market regulators are beginning to turn their attention to virtual...more

SEC Releases Guidance on Near-Term Disclosure Regarding Effects of New Tax Law

The tax reform signed into law by President Trump on Dec. 22 (the Tax Act) presents public companies with several accounting and disclosure challenges. Although companies are still evaluating how they will be affected by the...more

Funds Talk: May 2017 - Securitization Rules Offer Differing Definitions of ‘U.S. Person’

With the long-awaited U.S. rules requiring a level of risk retention in securitizations recently going into effect, an added wrinkle has been created by a slight difference in how “U.S. person” is defined in different...more

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