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Author: C. Dirk Peterson

Are Unregistered Trading Funds And Discretionary Asset Managers Securities Dealers? A Rule Proposal May Treat Them So

Mon 04 Apr, 2022  /  by C. Dirk Peterson   /   Client Alerts

INTRODUCTION Unregistered trading funds and discretionary asset managers have historically operated in the asset management sector and not as securities dealers subject to the comprehensive broker-dealer regulatory regime of the Securities Exchange Act of 1934 (“Exchange Act”) and rules of self-regulatory organizations (“SROs”). The Securities and Exchange Commission (“SEC” or […]

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It’s Not Just Gasoline Shortages – A $1.5 Million Reminder that Cybersecurity Policies Are Hand-In-Glove with Anti-Money Laundering Protocols

Tue 18 May, 2021  /  by C. Dirk Peterson   /   Client Alerts

DOWNLOAD PDF I.    INTRODUCTION The hacking of Colonial Pipeline inflicted painful costs in the form of regional gasoline shortages, panic hoarding, price gouging, and a temporary halt in distribution systems. Contemporaneous to the unfolding events surrounding the unauthorized access to Colonial Pipeline’s electronic distribution network, the Securities and Exchange Commission […]

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FINRA Settlement Affirms the Importance and Enforcement of Insider Trading Policies

Tue 27 Apr, 2021  /  by C. Dirk Peterson   /   Client Alerts

DOWNLOAD PDF A recent FINRA settlement should remind firms of the protective benefits of developing and enforcing robust insider trading policies and procedures [ FINRA Letter of Acceptance, Waiver, and Consent No. 2020067348501 (April 6, 2021)]. Among other things, the federal securities laws expressly require securities and investment advisory firms […]

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