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Some ruminations on the JOBS Act’s Regulation D provisions

Leonard, Street and Deinard
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USA
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March 29 2012

The Dodd-Frank Act was overarching, cumbersome and, from its inception, has created much ongoing regulatory uncertainty

More SEC color on current investment advisers issues

Leonard, Street and Deinard
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USA
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February 17 2011

In keynote remarks given at the PLI Investment Management Institute last week, SEC Commissioner Elisse B. Walter reiterated her support for the “need to protect retail investors seeking investment advice by harmonizing the regulation of investment advisers and broker-dealers” and increased attention to the exam process

Dodd-Frank vs. reality

Leonard, Street and Deinard
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USA
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January 3 2011

Last week the SEC "was persuaded" to extend the compliance date for Dodd-Frank Act's requirement that registered investment advisers provide their clients with brochure supplements written in plain English

Will whistleblower claims give rise to more SEC enforcement actions?

Leonard, Street and Deinard
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USA
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December 9 2010

The Dodd-Frank Act's whistleblower protection provisions will go into effect no later than nine months after July 22, 2010

FINRA to SEC: “no need to reinvent the wheel”

Leonard, Street and Deinard
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USA
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November 11 2010

Not surprisingly, FINRA strongly supports the creation of a new self-regulatory organization to enhance the frequency of examinations of investment advisers - one based on the structure FINRA uses to regulate broker-dealers

FINRA ups the retail customer disclosure ante

Leonard, Street and Deinard
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USA
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October 28 2010

The Dodd-Frank Act clearly emphasized the need to clarify the ongoing confusion, especially in the eyes of the retail investing public, of the distinctions between broker-dealers and investment advisers

SEC publishes golden parachute rule release

Leonard, Street and Deinard
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USA
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October 19 2010

Yesterday, as part of its "Say on Pay" rulemaking proposals, the SEC released its proposed rules for disclosure of golden parachute arrangements in the transactional context in which proxies are solicited

Sarbanes-Oxley prevents indemnification for clawback claims - Dodd-Frank implications

Leonard, Street and Deinard
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USA
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October 8 2010

Sarbanes-Oxley requires executives to reimburse their public company employers for bonuses and profits realized from the sale of company stock for the 12 month period following the filing of a false financial report that requires a financial statement restatement

SEC soon not to be free to keep certain information confidential

Leonard, Street and Deinard
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USA
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September 27 2010

One of the more controversial provisions of the Dodd-Frank Act allows information gathered by the SEC in its examination and investigation of those entities it regulates to not be subject to disclosure under the Freedom of Information Act