Search for: "JAY R. GOULD"
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12 Jun 2012, 3:45 pm
Written by: Jay Gould and Peter Chess The Financial Industry Regulatory Authority (“FINRA”) released new guidance last month regarding new FINRA Rule 2111 (the “Suitability Rule”), which requires a broker-dealer to have a reasonable basis to believe that a recommended transaction or investment strategy involving a security or securities is suitable for the customer, based on the information obtained through reasonable diligence by the broker-dealer. [read post]
25 Oct 2009, 6:01 pm
Stephen Jay Gould, no creationist, said: I shall be defending Ussher's chronology as an honourable effort for its time and arguing that our usual ridicule only records a lamentable small-mindedness based on mistaken use of present criteria to judge a distant and different past Ussher represented the best of scholarship in his time. [read post]
28 Jul 2011, 12:49 pm
Written by Jay Gould Pillsbury’s Investment Funds & Investment Management team has submitted a comment letter to the California Department of Corporations (the “DOC”) on behalf of the California Hedge Fund Association in connection with the DOC’s recently proposed amendments to the California custody rule. [read post]
2 May 2011, 10:46 am
Written by Jay Gould, Ildi Duckor and Michael Wu On March 22, 2011, U.S. [read post]
7 Apr 2014, 5:30 pm
s bio of Jay Gould, I struck upon a remarkable parallel. [read post]
12 Jul 2011, 4:16 pm
Written by Jay Gould, Ildiko Duckor and Michael Wu Effective on September 19, 2011, investors that pay performance fees to an adviser must either have at least $1 million managed by the adviser or a net worth of at least $2 million. [read post]
24 Jul 2012, 10:27 am
Written by: Jay Gould and Peter Chess In a July 10, 2012, no-action letter[1], available here, issued by a Division of the U.S. [read post]
29 May 2012, 11:28 am
Written by: Jay B. [read post]
15 Oct 2012, 3:11 pm
Written by: Jay Gould and Peter Chess Heath Abshure, President of the North American Securities Administrators Association (NASAA) and Arkansas State Securities Commissioner, sharply criticized the Securities and Exchange Commission’s (the SEC’s) new rulemaking that will lift restrictions on general solicitation and general advertising for hedge funds and other private investment vehicles in a press-teleconference on October 9, 2012. [read post]
4 Sep 2012, 5:15 pm
Written by: Jay Gould On August 30, 2012, the Securities and Exchange Commission (the “SEC”) released the Dodd Frank Act’s mandated study (the “Study”) on the financial literacy of retail investors which concludes, as you might have predicted, that retail investors are essentially clueless about investing and financial matters generally. [read post]
15 Nov 2011, 9:12 am
Written by Jay Gould On October 18, 2011, the SEC released a notice of FINRA’s filing of Proposed Rule 5123 (the “Proposed Rule”) which would require FINRA members and associated persons to: 1) provide to investors disclosure documents in connection with private placements prior to sale and 2) file with FINRA such disclosure documents within 15 days after the date of first sale and any subsequent amendments. [read post]
3 Feb 2012, 8:43 am
Written by Jay Gould and Peter Chess On January 18, 2012, the Office of Investment Adviser Regulation, part of the Division of Investment Management, issued a no-action letter (the “2012 Letter”) in response to a request for guidance from the American Bar Association’s Subcommittee on Hedge Funds on issues regarding the registration of certain investment advisers that are related to investment advisers registered with the Securities and Exchange Commission (the… [read post]
14 Mar 2012, 10:28 am
Written by Jay Gould, Michael Wu and Peter Chess The Commodity Futures Trading Commission (the “CFTC”) recently amended its registration rules regarding Commodity Pool Operators (“CPOs”) and Commodity Trading Advisors (“CTAs”), which will require many general partners and managers of private investment funds that previously relied on an exemption from registration to now register with the CFTC. [read post]
24 Apr 2012, 12:02 pm
Written by: Jay B. [read post]
23 Oct 2012, 3:07 pm
Written by: Jay Gould and Peter Chess While you were touring the Champagne region or sipping umbrella drinks at the beach this summer, the California Department of Corporations (the “DOC”) was busy overhauling the rules applicable to investment advisers. [read post]
8 Aug 2014, 5:00 am
Lawyers as SEC Enforcement Targets, What a Fund Manager Needs to Know by Jay B. [read post]
7 Feb 2012, 9:11 am
Written by: Jay Gould and Peter Chess 1. [read post]
30 Jan 2013, 2:38 pm
San Francisco Corporate & Securities partner Jay Gould is quoted in Compliance Week on new investor accreditation practices associated with the JOBS Act. [read post]
4 Jan 2009, 7:10 am
"Thematic pairs" is the term introduced in Michael Shermer, Science Friction: Where the Known Meets the Unknown (Time Books 2005) at 258, to describe five deep themes that appear ubiquitously in the hundreds of articles and essays written by the polymath paleontologist, Stephen Jay Gould. [read post]
27 Oct 2009, 12:34 pm
Jay Bybee: Well, we know why he's recused from the rendition case … Ninth Circuit Judge Jay Bybee isn't participating in a critical case about the state secrets privilege. [read post]
