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Expect Focus - Volume II, May 2025

Builder of Investment Models Deviates From Blueprints Employee’s Rogue Remodeling Costs Builder Plenty - The SEC’s recent order instituting administrative and cease-and-desist proceedings (OIP) against registered...more

Is SEC Whistleblower Program Topping Out?

Since its establishment more than a dozen years ago, the SEC’s whistleblower program has grown substantially — in terms of the number of whistleblower tips received by the SEC, as well as the number and dollar amount of...more

SEC Deep-Sixes Its Expanded “Dealer” Definition

Last year, the Securities and Exchange Commission amended its definition of “dealer” to require broker-dealer registration by some persons or entities previously considered securities “traders” not subject to such...more

Immediate Practical Consequences of SEC-Related EOs

A large number of the executive actions, including executive orders (EOs) and memoranda, that President Trump has been issuing can have important consequences for companies that make filings or have other business with the...more

Expect Focus - Volume I, January 2025

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence - In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church &...more

Piecing Alpine Together

Is FINRA constitutional? According to the D.C. Circuit’s November 2024 opinion in Alpine Securities Corp. v. FINRA, FINRA proceedings may be unconstitutional in one narrow set of circumstances. ...more

Can Shareholders Rescind an Investment Company’s Contracts Based on 1940 Act Violations?

Section 47(b) of the Investment Company Act of 1940 provides that contracts that violate or “whose performance involves, a violation of” the act are not enforceable by “either party.” ...more

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence

In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church & Dwight Co. fatally undermined Craigie’s status as an “independent director” of the company under New...more

Fifth Circuit Breaks From No-Action Pack: Becomes Better Bet for Letter Recipients?

On July 21, 2023, a three-judge panel of the Fifth Circuit Court of Appeals issued an opinion asserting that the Commodity Futures Trading Commission’s Division of Market Oversight likely acted arbitrarily and capriciously,...more

FINRA Targets Variable Annuity Practices

FINRA’s reported enforcement actions as to certain variable annuity practices increased in 2018. For example, FINRA announced more than half a dozen settlements – via Letters of Acceptance, Waiver and Consent (AWCs) – for...more

Veil Parted on SEC Whistleblower Award

Early this year, the SEC announced it had paid a whistleblower award of “more than $700,000” to a company “outsider” who “conducted a detailed analysis” that led to a successful enforcement action against the company....more

Expect Focus - Catching The Next Wave, Regulatory and Litigation Developments - Volume II, Spring 2014

In This Issue: - IN THE SPOTLIGHT ..Private Equity: The Next Wave of SEC Enforcement Actions? - LIFE INSURANCE ..How to Fight a STOLI Scheme: Court Rulings Offer Clues ..STOA Schemes Face...more

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