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Repairing A “Crack” in Insider Trading Regulation: SEC Rule 10b5-1 Trading Plans Face Increased Scrutiny

SEC Rule 10b5-1 plans have long provided an effective means for corporate insiders to buy and sell their own company’s securities without fear of civil or criminal insider trading liability, but these plans have come under...more

SEC Kicks Off 2021 Agenda With Intense Focus on ESG Disclosures

The global COVID-19 pandemic, severe weather events, and the social unrest unleashed in the United States over the past year have amplified the role of Environmental, Social and Governance (“ESG”) as a driving factor in...more

SEC’S Expansive View of “Accounting Controls” Draws Unusual Dissent from Two Commissioners

On October 15, 2020, the Securities and Exchange Commission issued a settled administrative order charging Andeavor LLC with failing to devise and maintain adequate internal controls surrounding its buyback of company stock...more

What is New After Liu: Unsettled Questions Surrounding SEC Disgorgement

On June 22, 2020, in Liu v. SEC, the Supreme Court held in an 8-1 decision that the SEC is authorized under 15 U.S.C. § 78u(d)(5) (2015) to seek disgorgement as “equitable relief” in district court actions, as long as the...more

FINRA Incentivizes Member Firms to Self-Report and Remediate 529 Plan Deficiencies

On January 28, 2019, FINRA announced a novel leniency initiative that will offer no-fine enforcement resolutions for member firms that self-report supervisory deficiencies related to recommendations of 529 savings plans and...more

Recent SEC Enforcement Actions Reinforce the Importance of Effective Supervision, Policies, and Procedures for Broker-Dealers and...

A summer of Securities and Exchange Commission settlements involving registered broker-dealers and investment advisers demonstrates that the SEC remains firmly committed to regulating the conduct of these firms. These...more

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