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US District Court Vacates Controversial Dealer Rules

On November 21, 2024, the US District Court for the Northern District of Texas vacated rules adopted by the Securities and Exchange Commission (SEC) in February 2024. Those rules had defined language in the definitions of...more

SEC Adopts New Rules That Will Require More Market Participants to Register as Dealers

On February 6, 2024, by a vote of 3-2 along party lines, the Securities and Exchange Commission (the SEC or the Commission) adopted Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (the Exchange Act), which...more

The Second Circuit's Blaszczak Decision Fails to Resolve One Issue, Raises New Ones

On December 27, 2022—nearly 18 months after hearing oral arguments—the Second Circuit issued its new opinion in United States v. Blaszczak, an important insider trading case involving the misappropriation of confidential...more

Getting Ready for Amended Rule 10b5-1 and Other New SEC Requirements Relating to Insider Trading

In December 2022, the Securities and Exchange Commission (SEC) adopted amendments to Exchange Act Rule 10b5-1, the rule that provides an affirmative defense to claims of insider trading for persons acquiring or disposing of...more

SEC Proposes Monthly Short Sale Reporting and Aggregated Public Disclosure

On February 25, 2022, the Securities and Exchange Commission (SEC) proposed Rule 13f-2 under the Securities Exchange Act of 1934 (the Exchange Act) and the corresponding Form SHO, which, if adopted, would require...more

SEC Insider Trading Enforcement Highlights from 2021

The Securities and Exchange Commission’s (SEC or Commission) actions in 2021 demonstrate that insider trading remains a key enforcement priority. While the absolute number of insider trading enforcement actions brought by the...more

Insider Trading Case to Watch: The Second Circuit to Revisit Blaszczak

This spring, the Second Circuit will revisit its highly consequential insider trading decision in United States v. Blaszczak. The case is one to watch, as it has the potential to impact how the government approaches...more

Congress Amends Exchange Act, Expanding SEC Enforcement Power

On January 1, 2021, amendments to Section 21(d) of the Securities Exchange Act of 1934 (Exchange Act) codifying and expanding the power of the Securities and Exchange Commission (SEC or Commission) to obtain disgorgement in...more

Insider Trading Prohibition Act Passed by the House of Representatives

Last week, a large, bipartisan majority of the US House of Representatives passed a bill that would explicitly codify a ban on insider trading, with 410 votes in favor of the bill and 13 against (12 Republicans and one...more

Insider Trading Law Alert: Better The Devil You Know? Tipping Liability, Martoma and the Rise of 18 U.S.C. § 1348

Insider trading has frequently been splashed across headlines in recent months, with a congressman, an NFL player, a comedy writer, and a Silicon Valley executive all facing charges. In the background of these headlines are...more

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