Michael E. Plunkett

Looking back – 2013 SEC comment letter trends

USA - January 3 2014 As we look forward to the upcoming 2014 10-K and proxy season, I like to take a look back at the crop of comment letters issued by the Securities…

Breaking bad (boy): SEC issues felon and “bad actor” disqualification guidance

USA - November 14 2013 The staff of the SEC released a Small Entity Compliance Guide discussing the application of the newly adopted regulations on the disqualification of…

Yelena M. Barychev, Francis E. Dehel, Melissa Palat Murawsky

The SEC and FINRA issue proposed crowdfunding rules

USA - October 28 2013 On October 23, 2013, the Securities and Exchange Commission released the long-awaited proposed crowdfunding rules necessary to implement Title III of…

Focus on business continuity and disaster recovery

USA - August 30 2013 The Securities and Exchange Commission seems to be awfully worried about disasters lately. On August 16, 2013, the SEC joined the Commodity Futures…

To use or not to use general solicitation and general advertising in private placements?

USA - July 30 2013 The SEC's July 10 meeting has fundamentally changed the world of private placements by eliminating the blanket prohibition against general…

Yelena M. Barychev, Francis E. Dehel, Melissa Palat Murawsky