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Investment Management and Private Funds Roundtable: TALF 2020 and PPP Update
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This article is the second of a three-part series discussing trusts in the context of certain common investor thresholds for investment in private securities. This article will examine trusts as “qualified clients” under the...more
Seyfarth Synopsis: The Securities and Exchange Commission currently takes the view that "finders" who introduce potential investors to a company must register as brokers if they receive compensation based on the amount of...more
The U.S. Securities and Exchange Commission (SEC) proposed a new exemptive order on Wednesday, October 7, which would exempt certain “finders” from broker-dealer registration under Section 15(a) of the U.S. Securities...more
Yesterday's big news at the Securities and Exchange Commission was a proposed exemptive order for finders. The question of whether issuers can compensate anyone other than a registered broker for finding investors has...more
An increasingly sophisticated and active OCIE division, innovative market disruptors, a maturing credit cycle, and a philosophical change in how the private fund industry views and utilizes litigation are likely to lead to...more
Last week, former CFTC Chairman Gary Gensler explained in remarks at M.I.T. that he believes the second and third most widely used virtual currencies—Ether and Ripple—may have been issued and traded in violation of securities...more
When looking to raise capital, broker-dealer compliance may not be at the forefront of a private fund manager’s mind. However, engaging individuals (including the fund manager’s employees) or firms to identify, introduce or...more
The U.S. Securities and Exchange Commission (“SEC”) recently approved a Financial Industry Regulatory Authority (“FINRA”) proposal to adopt a new regime for the regulation of electing broker-dealer firms that meet the...more