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6 Feb 2012, 5:07 pm
And this strikes me as highly problematic. [read post]
7 Jan 2015, 6:01 am
Many people (and apparently SEC examiners) skip over footnote 10 that states that the SEC assumes that the SPVs in the four scenarios are investment advisory clients. [read post]
21 Jun 2022, 3:30 am
I read the SEC’s climate disclosure proposals shortly after they were issued in order to prepare an article for The Corporate Counsel newsletter. [read post]
14 Sep 2009, 2:43 pm
" My superiors always overruled me, thankfully for the rule of law, but really, parsing deals like Rakoff is doing here does no one any good. [read post]
20 Apr 2015, 10:00 am
Ceresney, Director of the SEC’s Division of Enforcement, stated, “SEC rules prohibit employers from taking measures through confidentiality, employment, severance, or other type of agreements that may silence potential whistleblowers before they can reach out to the SEC. [read post]
22 Apr 2015, 2:13 pm
He also stated that it is “really not appropriate for me to bless any language,” and suggested that the same language could be acceptable in one context but not in another depending on the company’s approach to encouraging employees to come forward to report alleged securities fraud. [read post]
2 May 2012, 8:19 am
(Passing notes saying “HELP ME”?) [read post]
22 May 2013, 10:35 am
The language of Rule 206(4)-5 neither prohibits nor restricts investment advisors from contributing to federal candidates who presently hold no state or local office – only state "officials" from a "government entity" who have the power to directly or indirectly influence the outcome of the hiring of investment advisors (check out page 43 of the SEC's link above if you don’t believe me). [read post]
2 Feb 2010, 1:57 pm
The usual remedies are sought: injunction and civil penalty.A short article ran last week in AmLaw, however, that brought me back to the SEC complaint itself. [read post]
24 Oct 2019, 2:40 pm
Please contact me directly if you would like to submit a guest post. [read post]
25 Jan 2011, 6:09 pm
Be with you in a sec. [read post]
5 May 2009, 9:01 pm
Sec. 3-110e to read: Nathan Hale and Paul Newman shall be the state heroes. [read post]
22 Jun 2018, 5:57 am
In her majority opinion, Justice Elena Kagan held that administrative law judges are officers of the United States, not employees, and so they have to be appointed under the Constitution’s appointments clause. [read post]
18 Feb 2015, 3:20 am
Specifically, the lower likelihood of SEC enforcement actions against labor-intensive firms is more pronounced in presidential election years and is concentrated in “politically important states” – i.e., closely contested states with high Electoral College counts. [read post]
1 Aug 2022, 9:42 am
As for “disingenuous,” let me give you some examples: An SEC official has stated that the recent proposal on climate change disclosure was not intended to change the definition of materiality. [read post]
2 Jul 2014, 4:05 am
The SEC stated that it expects investment advisors and proxy advisory firms to conform their systems and processes in advance of next year’s proxy season. [read post]
22 Jun 2020, 4:17 pm
Please contact me directly if you would like to submit a guest post. [read post]
2 May 2023, 9:01 pm
I also had a career shift that took me to Greenwich, Conn., that fateful weekend in 1998 prior to Long-Term Capital Management’s failure. [read post]
16 Nov 2023, 4:10 pm
“OK, please let me know if there’s anything we should still do,” Mr. [read post]
28 Nov 2021, 6:53 am
Morgan, as Bear Stearns successor in interest, appealed the ruling to the New York Court of Appeals, the state’s highest court. [read post]
