The Second Circuit Court of Appeals ruled that plaintiffs cannot assert securities laws claims for foreign-issued shares purchased on a foreign exchange, even if the shares are cross-listed on a U.S. exchange or the "buy order" was placed within the United States. In Morrison v. National Australia Bank Ltd., 561 U.S. 247 (2010), the Supreme Court held that the anti-fraud provisions of Exchange Act Section 10(b) ("Manipulative and Deceptive Devices") and Exchange Act Rule 10b-5 ("Employment of Manipulative and Deceptive Devices") cannot reach purchases of foreign-issued securities by foreign

At a conference sponsored by the Council of Institutional Investors, SEC Commissioner Kara Stein spoke about ways in which the SEC can make the markets more efficient by better informing and empowering investors. Commissioner Stein stated that federal securities laws are based on the premise that an informed investor is the key to robust and efficient markets, noting that evaluating disclosure requirements is one area where the SEC needs to reexamine its current practices. In doing so, she stated, the SEC should not focus on removing redundancies and outdated disclosures. Instead, it should

During a hearing on the state of the international financial system, House Financial Services Committee Chairman Jeb Hensarling (R-TX) called on Secretary of the Treasury and Financial Stability Oversight Council ("FSOC") Chair, Jacob Lew, to "cease and desist" from designating more financial firms as "too big to fail" until there is an opportunity for greater congressional oversight of the FSOC's decision-making process. According to Chairman Hensarling, there "is increasingly bipartisan concern about the immense discretionary power that FSOC has and how frankly little transparency it has,"

The Financial Stability Oversight Council ("FSOC") issued its 2014 Annual Report, which describes significant financial market and regulatory developments identified by FSOC, analyzes emerging potential threats and makes certain recommendations. The report discusses: vulnerability to runs in wholesale funding markets, including tri-party repo and money market mutual funds, which can lead to destabilizing fire sales; developments in financial products and new business practices and in the migration of certain financial activities outside of the regulatory perimeter; the potential risk-taking

The SEC Office of Investor Education and Advocacy issued an Investor Alert intended to make investors aware of the potential risks of investments involving Bitcoin and other forms of virtual currency. The Investor Alert describes Bitcoin and its properties, explaining that investments involving Bitcoin may lead to a heightened risk of fraud. The Investor Alert also provides additional resources to further explore the topic, including links to past SEC and FINRA Investor Alerts on digital currency, IRS Virtual Currency Guidance , and recent lawsuits and cases involving virtual currency. See