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Category: Securities Regulation

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… [Click to Read More]


Proposed Disclosure of Cybersecurity Events

Thu 10 Mar, 2022  /  by C. Dirk Peterson   /   Client Alerts

DOWNLOAD PDF REGULATORY PROPOSAL Over the past decade, the Securities and Exchange Commission (“SEC”) and its staff have addressed cybersecurity threats and their escalating risk to commerce. Routinely cited as an examination priority, the SEC has now proposed standardized disclosure requirements of material cybersecurity events and cybersecurity protocols for public-reporting… [Click to Read More]


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]