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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   /   Securities Regulation

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   /   Securities Regulation

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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SEC Reforms Investment Advisers Act Regulation of Marketing Practices

Wed 30 Dec, 2020  /  by C. Dirk Peterson   /   Securities Regulation

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 […]

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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 […]

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What Small and Bank-Affiliated Insurance Entities Need to Know About State Exemptions from Insurance Data Security Laws

Sat 10 Oct, 2020  /  by Chrys Lemon, Arshawn Teymoorian, and Jeff Klein   /   Securities Regulation

DOWNLOAD PDF On October 24, 2017, the National Association of Insurance Commissioners (“NAIC”)1 adopted Model Law No. 668, the Insurance Data Security Model Law (the “Model Law”).2 Generally speaking, the Model Law requires entities regulated by state insurance departments to develop and implement an Information Security Program (“ISP”) to protect […]

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