Securities and Exchange Commission (SEC), No-Action Letters, Policies and Procedures

SEC grants no action relief from paragraph (a)(3)(iii) of Rule 192

Hogan Lovells on 6/9/2025

The Securities and Exchange Commission has issued a no-action relief letter regarding paragraph (a)(3)(iii) of Rule 192 under the Securities Act of 1933, as amended. Rule 192, finalized in January 2024, implements Section 621...more

Broker Dealer Regulatory Digest - September 2023

Davis Wright Tremaine LLP on 9/22/2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

SEC Adopts Final Auditor Independence Loan Rule

Faegre Drinker Biddle & Reath LLP on 7/9/2019

On June 18, 2019, the Securities and Exchange Commission (“SEC”) adopted final amendments to Rule 2-01(c)(1)(ii)(A) of Regulation S-X (the “Loan Rule”) to clarify the analysis that must be conducted to determine whether an...more

ESG Investor Walden Scores Win on CorVel Shareholder Proposal Re LGBTQ Rights

Robins Kaplan LLP on 6/18/2019

On June 5, 2019, the Securities and Exchange Commission (SEC) declined to issue a no-action letter to CorVel Corporation with respect to CorVel’s intention to exclude from its proxy materials a shareholder proposal regarding...more

SEC Staff Eases Fund Director Burdens

A&O Shearman on 10/17/2018

For decades, mutual fund directors have turned to quarterly reports on affiliated cross trades, participation in affiliated underwritings and affiliated brokerage; the reports themselves state that the trades are in...more

Citizen.VC No Action Letter: Clarity and Guidance for Conducting a Private Placement Online

Mintz on 8/10/2015

The SEC has recently provided clarity as to how an issuer of securities can conduct a private placement in a password protected web page under Rule 506(b), without it being deemed a “general solicitation” and thereby being...more