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23 Apr 2015, 3:33 am by Broc Romanek
Meanwhile, this page lists 6 Twitter handles for the SEC, including two of the regional offices having their own handles… Private Placement Brokers: FINRA Highlights In Annual Exam Letter As covered in this Morrison & Foerster memo, FINRA has published a longer annual priorities letter than it typically does – and tackles a number of issues related to private placements including: – Inadequate due diligence by broker-dealers in connection with private placements –… [read post]
22 Apr 2015, 4:06 am by Broc Romanek
Fraud Indicators: Signature Size Matters This article notes how a recent study shows that CFOs with big signatures are more likely to misreport… – Broc Romanek [read post]
21 Apr 2015, 4:07 am by Broc Romanek
As noted in this memo, the major changes are: – Revise the definition of “intended loss” at §2B1.1, comment (n.3(A)(ii)) to mean the pecuniary harm “that the defendant purposely sought to inflict” – Revise the victims table at §2B1.1(b)(2) to incorporate “substantial financial hardship” as a sentencing enhancement factor – Revise the meaning of the specific offense characteristic for “sophisticated means” contained in… [read post]
14 Apr 2015, 3:44 am by Broc Romanek
I imagine using nomenclature consisting of last names would go the way of the Dodo… – Broc Romanek [read post]
10 Apr 2015, 6:29 am by Broc Romanek
” Also see the blog I just posted on “The Proxy Blog” running down the stats of how 64 of the companies that received proxy access proposals handled them… – Broc Romanek [read post]
6 Apr 2015, 3:25 am by Broc Romanek
Didn’t see Taiwan’s SEC – but did run across the Treasury building: And this museum certainly seems unique: This video highlights the use of scooters to get around & the popularity of basketball (including among women, who were playing everywhere – nearly as much as the men): – Broc Romanek [read post]
23 Mar 2015, 3:29 am by Broc Romanek
See this McGuireWoods memo… Speaking of comments, the ABA’s Business Law Section has submitted a comment letter on the S-K portion of the Corp Fin’s Disclosure Effectiveness project… – Broc Romanek [read post]