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Category: Client Alerts

NAIC Task Force Tackles Patchwork of Anti-Rebating State Laws and Adopts Revisions to NAIC Model Law

Thu 10 Jun, 2021  /  by Chrys Lemon and Arshawn Teymoorian  /   Client Alerts

DOWNLOAD PDF Rebating is where an insurer or insurance agent gives something of value as an inducement to purchase insurance that it not included in the policy itself, such as when a prospective insurance customer receives a refund of part of the commission from an insurance sale. State anti-rebating laws… [Click to Read More]


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… [Click to Read More]


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… [Click to Read More]


SEC Reforms Investment Advisers Act Regulation of Marketing Practices

Wed 30 Dec, 2020  /  by C. Dirk Peterson   /   Client Alerts

DOWNLOAD PDF Updated: March 26, 2021 New Rule 206(4)-1 – Adviser Marketing Introduction The Securities and Exchange Commission (“SEC” or “Commission”) delivered on highly anticipated regulatory reforms relevant to the marketing practices of investment advisers registered pursuant to, and regulated by, the Investment Advisers Act of 1940 (“Advisers Act”). The… [Click to Read More]


The SEC Proposes a Limited Exemption to deregulate Capital Raising Efforts

Wed 14 Oct, 2020  /  by C. Dirk Peterson   /   Securities Regulation

In a nod to both Wall Street and Main Street, the SEC recently proposed an order to deregulate certain capital-raising efforts for private issuers. The proposal prescribes conditions to permit natural-person finders to raise capital for issuers absent the finder submitting to the substantive broker-dealer registration and regulatory regime prescribed… [Click to Read More]