A Securities and Exchange Commission (“SEC”) plan to create a registration exemption for certain finders has generated a mixed response. The nearly 90 comments received by the SEC by the November 12, 2020 close of the comment...more
In Securities & Exchange Comm. v. Gentile, No. 18-1242, 2019 WL 4686251 (3d Cir. Sept. 26, 2019), the United States Court of Appeals for the Third Circuit took up the question of whether Securities and Exchange Commission...more
10/17/2019
/ Appeals ,
Broker-Dealer ,
Enforcement Actions ,
Future Harm ,
Injunctions ,
Injunctive Relief ,
Penalties ,
Penny Stocks ,
Pump and Dump ,
Remand ,
Reversal ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Statute of Limitations ,
Statutory Authority
Earlier this month, the Securities and Exchange Commission (“SEC”) took a break from its recent focus on digital assets and the Best Interest fiduciary standard to publish a Risk Alert encouraging investment advisers and...more
4/30/2019
/ Broker-Dealer ,
Customer Information ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Investment Adviser ,
OCIE ,
Opt-Outs ,
Policies and Procedures ,
Privacy Policy ,
Regulation S-P ,
Regulatory Requirements ,
Risk Alert ,
Securities and Exchange Commission (SEC)
On January 22, 2019, the Financial Industry Regulatory Authority, Inc. (“FINRA”) released its annual priorities letter highlighting its regulatory program’s points of emphasis for the coming year. The most immediately...more
1/31/2019
/ Broker-Dealer ,
Digital Assets ,
Examination Priorities ,
Financial Industry Regulatory Authority (FINRA) ,
Fixed Income Investments ,
OCIE ,
Online Distribution ,
Online Platforms ,
Regulation A ,
Regulation D ,
Risk Management ,
Rule 506(c) ,
SEC Examination Priorities
On July 18, 2018, the SEC ramped up its oversight of alternative trading systems (“ATSs”) by adopting a series of rule amendments imposing public disclosure requirements on ATSs that trade NMS (“National Market System”)...more
9/27/2018
/ Alternative Trading System (ATS) ,
Amended Rules ,
Broker-Dealer ,
Confidential Information ,
Data Protection ,
Disclosure Requirements ,
Exemptions ,
Investors ,
National Market System (NMS) ,
Notice of Final Rulemaking ,
Public Disclosure ,
Registration ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Securities Exchanges ,
Securities Transactions ,
Stocks ,
Trading Platforms
The Security and Exchange Commission’s (“SEC”) recent $1 million settlement with Morgan Stanley Smith Barney LLC (“MSSB”) marked a turning point in the agency’s focus on cybersecurity issues, an area that the agency has...more
7/2/2016
/ Broker-Dealer ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Customer Funds Protection ,
Cybersecurity ,
Data Breach ,
Enforcement Actions ,
Investment Adviser ,
Misappropriation ,
Morgan Stanley ,
Personally Identifiable Information ,
Regulation S-P ,
Securities and Exchange Commission (SEC) ,
Settlement