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SEC Summarizes Regulation Best Interest And Form CRS Relationship Summary
If you were somewhat put off by the prospect of reading over 1,000 pages of adopting releases for Regulation Best Interest and the Form CRS relationship summary and amendments to Form ADV, you are now
United States
18 Oct 2019
Frequent Principal And Trading Agency Cross Transactions Compliance Issues
Section 206(3) makes it unlawful, with certain limited exceptions, for an investment adviser to directly sell or purchase securities to and from clients or to act as a broker for a third party effecting
United States
17 Oct 2019
The SEC's Regulation S-P In The Age Of Cybersecurity
Bylined article by Financial Services Regulatory & Enforcement partner Jeffrey Taft and associates Matthew Bizanz and Leslie Cruz.
United States
16 Oct 2019
Key Compliance Considerations From DOJ's New Redlining Settlement
Last month, the United States Department of Justice ("DOJ" or the "Department") settled redlining claims against First Merchants Bank, an Indiana-based bank regulated by the Federal Deposit Insurance Corporation.
United States
30 Jul 2019
FDIC Proposes Changes To Securitization Safe Harbor Rule
Many banks have not made the investments in their systems to be able to provide asset-level data under the Reg AB requirements.
United States
29 Jul 2019
US Department Of Justice Announces Incentives For Robust Antitrust Compliance Programs
On July 11, 2019, Assistant Attorney General Makan Delrahim announced important changes in how the Antitrust Division of the US Department of Justice (Division) would make a charging decision in criminal antitrust cases.
United States
25 Jul 2019
Planned Weekend Immigration Enforcement Actions Magnify Need For Employers To Focus On Preparedness And Compliance
US Immigration and Customs Enforcement has planned a series of nationwide raids this weekend to detain and remove thousands of undocumented immigrants, according to multiple national media reports.
United States
22 Jul 2019
Delaware Decision Breathes New Life Into Bad Faith Claims Against Directors: Practical Advice After Marchand V. Barnhill Allows Bad Faith Claim Based On Failure To Monitor Central Compliance Risks
In the recent case of Marchand v. Barnhill, the Delaware Supreme Court reversed the dismissal of a claim that the directors of Blue Bell Creameries USA, Inc.
United States
12 Jul 2019
US Antitrust Agencies Reject Parties' Corporate Deal Structure To Determine Alleged HSR Act Violations
On June 10, 2019, Toshiba Corporation ("Toshiba") and Canon Inc. ("Canon") agreed to settle a complaint filed by the Antitrust Division of the US Department of Justice
United States
28 Jun 2019
Regulation Best Interest
On June 5, 2019, the Securities and Exchange Commission (SEC) adopted Regulation Best Interest (Rule 15l-1 under the Securities Exchange Act of 1934 (Exchange Act)),
United States
25 Jun 2019
OCIE's Retail Investor Protection Focus
On April 29, 2019, Securities and Exchange Commission Office of Compliance Inspections and Examinations Director Peter Driscoll delivered a speech on the OCIE's 2019 priorities, in which he identified, among other priorities, the following:
United States
10 Jun 2019
OFAC Issues First Formal Guidance Framework On Sanctions Compliance Programs
On May 2, 2019, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") published A Framework for OFAC Compliance Commitments ("Framework").
United States
22 May 2019
OCIE Issues Regulation S-P Risk Alert For Advisers And Broker-Dealers
Privacy and the safeguarding of customer information continues to be an important compliance topic from the SEC's perspective, including its examination staff.
United States
14 May 2019
On Point. - Understanding The Requirements Related To The Use Of Non GAAP Financial Measures
It is no secret that the use of non-GAAP financial measures, which are financial measures that are neither calculated nor presented in accordance with U.S. generally accepted accounting principles
United States
8 May 2019
Follow-Up On Regulation S-K Modernization And Simplification
As described in our Legal Update "SEC Adopts Rules to Modernize and Simplify Disclosure," dated March 27, 2019,1 the US Securities and Exchange Commission (SEC) ...
United States
16 Apr 2019
US Department Of Justice Sharpens Its Focus On Foreign Lobbying And Influence
Two recent steps by the Department of Justice ("DOJ") demonstrate a new commitment to enforcing the Foreign Agents Registration Act ("FARA").
United States
21 Mar 2019
Proposed Legislation To Watch
There are a number of legislative proposals making their way through the House and the Senate that would affect public reporting companies and are gathering some momentum, so they bear watching.
United States
28 Feb 2019
REVERSEinquiries Volume 2, Issue 2
On January 22, 2019, FINRA issued its 2019 Risk Monitoring and Examination Priorities Letter1 (the "Letter") ...
United States
28 Feb 2019
OCIE's 2019 Examination Priorities And 2018 Enforcement Actions: Practice Points For Advisers To Consider
The US Securities and Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") released its 2019 examination priorities on December 20, 2018,
United States
27 Feb 2019
SEC Staff Releases Hedging Disclosure Compliance Guidance
The Staff of the Securities and Exchange Commission ("SEC") released a question and answer guide relating to the recently adopted rule amendments requiring disclosure of company policies ...
United States
27 Feb 2019
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