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Insider Trading Securities and Exchange Commission (SEC) Securities Regulation

Bass, Berry & Sims PLC

(Insider) Trading under a Rule 10b5-1 Plan

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In June 2025, Terren Scott Peizer, the former chief executive officer, executive chairman and chairman of the board of directors of Ontrak, Inc. (Ontrak), was sentenced to 42 months imprisonment, ordered to pay a $5.25...more

Cooley LLP

The Life of Former SEC Chair (and Corp Fin Director) Manny Cohen

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Recently, I blogged about the 20 Corp Fin Directors we’ve had at the SEC (we haven’t heard yet who will be the new Corp Fin Director) – and it got me thinking about Manny Cohen, whom many of us don’t know much about since he...more

Secretariat

Reflections on Initial SEC Policy Changes Early in the Atkins Era

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Since Paul Atkins became Chairman of the U.S. Securities and Exchange Commission (SEC) on April 21, 2025, the SEC has announced significant pivots in its approaches to enforcement, regulatory guidance, investment adviser...more

NAVEX

Watch Out for Hoax Reports to Your Hotline

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We’ve recently been made aware of an increase in anonymous hoax emails and online reports posted to multiple companies through their internal reporting systems. The wording of these posts were identical and alleged violation...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: June 1, 2025

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

Womble Bond Dickinson

Enforcement Priorities and Policy Changes Detailed at SEC Speaks Conference

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The U.S. Securities and Exchange Commission held its annual SEC Speaks conference on May 19 and 20, 2025, in Washington, D.C. On the second day of the conference, the Staff of the Division of Enforcement hosted two panel...more

Lowenstein Sandler LLP

Key Considerations for Alternative Data and AI Vendors to Investment Firms: Demonstrating Compliance in the Face of an Evolving...

The Securities and Exchange Commission (SEC) has previously provided guidance through risk alerts, proposed rules, and enforcement actions that outline expectations for registered investment advisers and other financial firms...more

Ropes & Gray LLP

SEC Speaks 2025: Key Takeaways from Division of Enforcement Panels

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The SEC’s Division of Enforcement intends to remain a “cop on the beat,” and will refocus on traditional core enforcement areas, such as insider trading, accounting and disclosure fraud, market manipulation, and breaches of...more

Bradley Arant Boult Cummings LLP

SEC Enforcement Leadership Discusses New Priorities and Expectations

On May 20, 2025, as part of the annual “SEC Speaks” program, the leadership of the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement publicly discussed the enforcement priorities under new Chairman Paul...more

Perkins Coie

Securities Enforcement Forum West 2025: Embracing Change in the SEC’s New Chapter

Perkins Coie on

Key Takeaways - - A return to traditional enforcement priorities is likely forthcoming under the new administration, with a shift away from creative and aggressive enforcement toward more “bread and butter” matters. -...more

Maynard Nexsen

Updated Compliance & Disclosure Interpretations on Rule 10b5-1

Maynard Nexsen on

On April 25, 2025, the Securities and Exchange Commission’s Division of Corporation Finance (the “SEC”) updated its Compliance and Disclosure Interpretations (“C&DI”) pertaining to Rule 10b5-1 trading plans, which provide an...more

BCLP

SEC Staff Updates Rule 10b5-1 Interpretations

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The SEC staff recently published updates to its interpretations (CDIs) for Rule 10b5-1 – the insider trading exemption for pre-established trading plans....more

Cooley LLP

Spring Cleaning for Corp Fin’s Rule 10b5-1 CDIs

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Last week, Corp Fin did some spring cleaning in the Rule 10b5-1 area by adding two new CDIs, revising 20 CDIs, and withdrawing three CDIs so they better jibe with the amendments to Rule 10b5-1 in 2022....more

Bradley Arant Boult Cummings LLP

SEC Enforcement in the First Quarter of the New Administration

The new presidential administration began on January 20, 2025, and change came quickly to many federal agencies, including the U.S. Securities and Exchange Commission (SEC). On Inauguration Day, Paul S. Atkins was nominated...more

Wilson Sonsini Goodrich & Rosati

Corp Fin Updates CDIs on Rule 10b5-1

On April 25, 2025, the U.S. Securities and Exchange Commission’s Division of Corporation Finance (Corp Fin) updated its Compliance and Disclosure Interpretations (CDIs) relating to Rule 10b5-1 by issuing two new CDIs,...more

Cooley LLP

How to Explain Section 16 to a Newbie

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Given the hubbub over the SEC’s new EDGAR Next, I thought it would be useful to provide a FAQ explaining the rationale for Section 16 to a new director or officer who is unfamiliar with the concept....more

DLA Piper

Reminders and New Disclosure Requirements for the 2025 Proxy Season

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The proxy statement has become an integral component of a public company’s preparation for its annual meeting of shareholders. The rules and regulations under the Securities and Exchange Act of 1934 (the Exchange Act),...more

McDermott Will & Schulte

New SEC Leadership Signals Continued Focus on FDA-Related Disclosures

Lawyers inside and outside the US Securities and Exchange Commission (SEC) have speculated that the agency’s new leadership will take a “lighter touch” when it comes to enforcement. The ultimate approach of the new SEC...more

Cooley LLP

SEC Now Requires Commission Approval for Subpoenas, but Says It Is Not ‘Walking Away’ From Enforcement

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On March 10, 2025, the US Securities and Exchange Commission (SEC) adopted a final rule that will require a majority of the Commissioners to agree before the SEC formally opens an investigation. For the past 15 years, that...more

Moore & Van Allen PLLC

“EU Listing Act Introduces Exemptions Allowing Insiders to Trade During Blackout Periods.”

On November 14, 2024, the EU Listing Act (the “Listing Act”) was published in the Official Journal of the European Union. The Listing Act entails a legislative package designed to improve capital markets access and enhance...more

Secretariat

SEC Enforcement Trends for 2025 — Shadow Trading, Artificial Intelligence (AI), and Crypto

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2024 was a pivotal year for SEC enforcement as the Commission significantly ramped up its efforts, filing 583 enforcement actions and obtaining $8.2 billion in financial remedies, a record for the agency....more

White & Case LLP

Key Considerations for the 2025 Annual Reporting and Proxy Season Part II: Proxy Statements

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Each year in our Annual Memo series, White & Case's Public Company Advisory Group provides practical insights on preparing Annual Reports on Form 10-Ks, Annual Meeting Proxy Statements and, for FPIs, the Annual Report on Form...more

Morrison & Foerster LLP

When Your Life Sciences Are on the Line: Securities Enforcement

Morrison Foerster partners Kate Driscoll and Nate Mendell, both former federal prosecutors and members of the firm’s Investigations + White Collar Defense Group, hosted the eighth episode of When Your Life Sciences Are on the...more

Morgan Lewis

Developments in SEC and FINRA Enforcement and Exams for Investment Advisers and Broker-Dealers: 2024–2025

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The US Securities and Exchange Commission (SEC) brought a number of significant enforcement proceedings against investment advisers and broker-dealers in FY 2024 and during the first quarter of FY 2025. If history serves as a...more

Foley Hoag LLP - White Collar Law &...

SEC Expected to Shift Priorities and Adopt a More Business-Friendly Approach in 2025

This is the fourth in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

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