Apparently, despite the Inspector General change, the SEC continues to be beset by problems with its internal operations that its Inspector General has recently pointed out. The OIG has detailed in several
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The JOBS Act Causing Clashes Between the Industry and Investor Groups
In recent days, industry and investor advocates have been fighting over the general solicitation and advertising exemptions in private placements that went into effect with the JOBS Act.
Further, these…
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Recent Legislative Initiatives. . . Yes, We Have Reached the Silly Season
Despite the fact people are still unemployed, the drought rages and farmers suffer, and the deficit continues to grow, Congress seems to float absurd legislation across the partisan divide to…
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Gatekeeper’s Beware. . . the SEC is Still after You
If anyone had forgotten, the SEC is still looking to prosecute compliance officers and legal counsel, who are considered gatekeepers, in aggressive enforcement actions. Although the SEC was unable to effectively delineate…
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SEC’s Business Continuity Issues Continue
Apparently, despite requiring public companies and regulated entities to prepare for business disruptions, the SEC’s house does not seem to be in order.
In a recent report, the SEC was criticized for…
WHAT HAPPENS WHEN THE SKY DOES IN FACT FALL IN ON YOU? EXPORT CONTROLS AND OTHER CUSTOMS ISSUES
We have repeatedly blogged about government investigations. Moreover, regardless of the election results, government investigations will continue. Further, these governement investigations take on a life of their own and almost always encompass several different…
Interesting Timeliness Case in the Southern District of New York
In an interesting procedural decision, the United States District for the Southern District of New York certified an interlocutory appeal regarding the 2008 Housing and Economic Recovery Act (“HERA”), as…
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No-Action Letter Permits Advisory Services to Affiliated Third Parties
In an interesting no-action letter, the SEC Staff stated it would not recommend enforcement action if a company did not register as an investment adviser where the company provided investment…
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Cockroaches, the NFL and Presidential Statistics. . . Another Silly Friday Prediction
Yes, this blog is quite different than what you are used to reading, but it is a Friday in August so please take it in that vein. Here goes.
Undoubtedly,…
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More on Gabelli. . . Fifth Circuit Refuses to Go Along
As a service to our readers, the United States Court of Appeals for the Fifth Circuit has rejected the Second Circuit’s analysis in Gabelli. See SEC v. Bartek, at …
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