The SEC issued a notice soliciting comments about the extension of information collected from investment advisers under Advisers Act Rule 206(3)-2 ("Agency Cross Transactions for Advisory Clients"). Rule 206(3)-2 applies to all SEC-registered investment advisers, and permits them to comply with Section 206(3) of the Advisers Act by obtaining a client's blanket consent to enter into agency cross-transactions. In relying on the rule, investment advisers must provide certain disclosures to their clients. SEC-registered advisers must maintain and preserve certain information that is required under

SEC Commissioner Daniel Gallagher delivered remarks at the Vanderbilt Law School's 17th Annual Law and Business Conference. He spoke about what he called the "critical capital formation issues" faced by the SEC. Commissioner Gallagher stated that while he is pleased with the SEC's recent adoption of changes to Regulation A+ ("Reg. A"), the rule is "not as good as it could have been." He encouraged companies to ensure Reg. A's success by reporting any inefficiencies in the regulatory scheme as they begin to use the new rules to raise capital. He also stated that while the revisions to Reg. A

The Washington State Securities Division issued a statement of inquiry indicating its plan to propose rules to preserve the filing requirements for offerings of securities made under Tier 2 of the SEC's newly adopted rules for Regulation A offerings. The SEC's new rules adopt a definition of "qualified purchaser" that extends to "any person to whom securities are offered or sold" in offerings of up to $50 million in a Tier 2 offering under federal Regulation A. According to the Washington State Securities Division, "while the effect of defining a 'qualified purchaser' in this manner is to

The SEC announced charges against a day trader who allegedly manipulated the securities of a microcap company in order to drive the company's stock price above the minimum required for listing on Nasdaq Capital Market. The SEC alleged that the day trader engaged repeatedly in marking-the-close trades and entered into matched trades in shares of Cyberdefender Corp., a now-defunct computer software company, in order to maintain the price of the company at or above $4.00 per share. According to the SEC, the day trader also profited from his scheme by more than $650,000, mainly by exercising

MFA submitted comments in response to the CFTC's reopened comment period regarding the proposed rulemaking on position limits for derivatives. The CFTC reopened the comment period to provide commenters with the opportunity to discuss (i) issues addressed at the CFTC Energy and Environmental Markets Committee ("EEMAC") meeting held on February 26, 2015, and (ii) the new provisions in Table 11a of the position limits proposal, which shows counts of unique persons over certain percentages of the proposed position limit levels based on counts from January 2013 to December 2014. MFA raised concerns