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Bob Zwirb Commentary by Bob Zwirb

The SEC announced an enforcement action against a company for offering complex derivatives products to retail investors without the required registration statements. According to the SEC, the Silicon Valley-based Sand Hill Exchange ("Sand Hill") invited Web users to buy and sell contracts referencing pre-IPO companies and their value. Sand Hill also sought people to fund accounts using dollars or bitcoins. According to the SEC, the two entrepreneurs who began the company did not ask Web users about their financial holdings or limit offerings to users with any specific amount of assets. The SEC

The SEC announced that the U.S. District Court for the Southern District of New York entered a consent judgment against a senior information technology professional for insider trading. According to an SEC Complaint filed against him in September 2014, the individual had access to non-public information stored in the firm's client-related databases and garnered more than $300,000 in illicit profits using this information to trade in advance of merger announcements involving the firm's clients. The SEC found that the individual used accounts in his own name to engage in insider trading at first

The Office of the Comptroller of the Currency ("OCC") issued a revised booklet titled "Residential Real Estate Lending." The booklet is part of the Comptroller's Handbook. The booklet, which replaces the "Real Estate Loans" and "Examination Procedures" booklets that were issued in March 1990 and March 1998, respectively, includes the following: Advisory Letter 1997-7, "Affordable Mortgage Portfolios," and OCC Bulletin 2005-3, "OCC Guidelines Establishing Standards for National Banks' Residential Mortgage Lending Practices: Appendix C to 12 CFR Part 30," both of which are made applicable to

The MSRB published a document that outlines considerations for developing a municipal advisory supervisory system and compliance program under MSRB Rule G-44. MSRB Rule G-44, which became effective on April 23, 2015, sets forth the basic requirements for municipal advisors to establish supervisory system and compliance programs. The MSRB released its new considerations document as a tool to assist municipal advisors in developing effective policies and procedures for supervision and compliance, particularly municipal advisors that are newly subject to regulatory oversight. See: MSRB

The SEC announced that a federal jury in Massachusetts convicted an individual of criminal charges of conspiracy and securities fraud. The charges stemmed from his role in an insider trading ring that traded on information about American Superconductor Corporation. The SEC had instituted a securities fraud action on the same matter in July 2014. According to the U.S. Attorney's Office for the District of Massachusetts, the individual learned of the information through a friend who provided him with material, non-public information concerning American Superconductor's quarterly earnings and