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SEC Commissioners Approve Proposal for Changes to Form PF

As anticipated in an earlier SECond Opinions post, the U.S. Securities and Exchange Commission (SEC) voted 3-1 today to approve proposed amendments to Form Private Fund (PF), a form the commission uses to collect data about...more

The SEC's Ears Remain Perked for an Abundance of Executive Perks

As we continue our review of FY 2021 SEC enforcement activity, we turn our attention to a topic that, if not already a key focus for publicly traded companies, should be. As part of their effort to recruit and retain...more

SEC to Vote Next Week on Proposing New Hedge Fund Disclosure Requirements

Enhanced disclosure requirements may be coming soon for hedge funds and private equity firms. U.S. Securities and Exchange (SEC) Commissioner Chair Gary Gensler said on Jan. 19, 2022, that the regulator will vote next week on...more

2021: Year In Review - SEC Signals More Aggressive Posture in Cybersecurity Space

We continue our year-end review of SEC enforcement activity and turn our attention to a topic grabbing seemingly daily headlines across multiple industries: cybersecurity. As the risks – and realities – of cyberattacks...more

"Shadow Trading" Case Survives Defendant's Motion to Dismiss

The U.S. District Court for the Northern District of California in SEC v. Panuwat, a case we discussed in a previous blog as having significant repercussions for insider trading enforcement in fiscal year (FY) 2022, just...more

Ripple Effects of Recent Discovery Decision in SEC v. Ripple Labs, Inc.?

We interrupt our regularly scheduled fiscal year (FY) 2021 SEC Enforcement overview to address a recent discovery opinion in the closely followed SEC v. Ripple Labs, Inc., et. al matter out of the U.S. District Court for the...more

The Future's Best Predictor: What Can FY2021 Insider Trading Actions Tell Us About FY2022?

Last month, Holland & Knight published an alert that broke down the SEC Division of Enforcement (Division) Annual Report for the fiscal year (FY) 2021...more

Highlights from the SEC Division of Enforcement FY 2021 Annual Report

The U.S. Securities and Exchange Commission's (SEC) Division of Enforcement (Division) published its Annual Report for Fiscal Year 2021 on Nov. 18, 2021. The Annual Report – the first issued under new Enforcement Director...more

Fifth Circuit: SEC's Plan for Distributing Disgorged Amounts to Investors Satisfies Liu

The U.S. Court of Appeals for the Fifth Circuit on Oct. 12, 2021, became the first federal appellate court to decide whether a disgorgement award entered against defendants in an U.S. Securities and Exchange Commission (SEC)...more

FINRA Issues Guidance on FinCEN AML/CFT Priorities

The Financial Industry Regulatory Authority (FINRA) issued a regulatory notice on Oct. 8, 2021, encouraging its broker-dealer members to review and prepare to incorporate into their own compliance programs the national...more

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