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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 […]


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 […]


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 […]