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At the 15th Annual A.A. Sommer Jr. Lecture on Corporate, Securities and Financial Law, SEC Commissioner Daniel M. Gallagher spoke about the future of the SEC, stating that it and the U.S. capital markets face an existential threat: "the encroaching imposition of so-called prudential regulation on markets wholly unsuited to that regulatory paradigm." The way that the SEC handles this encroachment, explained Commissioner Gallagher, will determine whether the SEC remains as relevant in the 21st century as it was in the 20th. Commissioner Gallagher identified two key "guideposts" that will ensure

The SEC published a Risk Alert and FAQs reminding broker-dealers of their obligations when engaging in unregistered transactions on behalf of their customers. The Risk Alert identifies a number of deficiencies that the SEC staff observed regarding compliance to certain obligations related to sales of securities of microcap companies. These include: insufficient policies and procedures for monitoring customer-initiated sales to identify potential red flags; inadequate controls to evaluate how customers acquired securities and whether the securities could be lawfully resold without registration

SEC Director of the Division of Corporation Finance ("Division") Keith Higgins delivered remarks before the George A. Leet Business Law Conference. He discussed SEC disclosure requirements and shared ideas on the future of disclosure. Mr. Higgins discussed the origin of disclosure requirements through the enactments of the Securities Act and Securities Exchange Act. He explained that two separate disclosure regimes emerged with often overlapping and duplicative requirements. According to Mr. Higgins, the goal of the Division's Disclosure Effectiveness agenda today is to recommend to the SEC

SIFMA submitted a response to the MSRB's request for comment on potential enhancements to the post-trade municipal securities transaction data that would be disseminated from a new central transparency platform ("CTP"). SIFMA stated that, while it was pleased with the "methodical manner" in which the MSRB proceeded to obtain input regarding the development of the CTP, it was concerned about the cost of certain elements of the proposal. In particular, SIFMA voiced concerns about the proposed addition of a conditional trading commitment indicator, as well as changes related to dealer