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District Court to SEC: seven-year investigation a bit (too) long for my jurisdiction enforcement action against alleged Ponzi schemers dismissed

USA - May 20 2014 The SEC must institute an enforcement action within five years of the accrual of the claims, including enforcement actions wherein the Securities and...

FINRA 2014 regulatory and examination priorities include “recidivist” brokers, conflicts of interest, frontier funds, crowdfunding portals

USA - January 7 2014 On January 2, 2014, the Financial Industry Regulatory Authority, Inc. (FINRA) released its annual letter (Letter) identifying its regulatory and...

SEC issues final rules eliminating prohibition on general solicitation of Regulation d offerings and implementing bar on Regulation D exemption for offerings with bad actor issuers or other relevant persons

USA - July 30 2013 In the past two weeks, the U.S. Securities and Exchange Commission (SEC) has issued two long-awaited final rules amending Rule 506, the most widely...

Michael M. Zmora, Michael B. Gray.

Attention private fund advisers: are you registered as a broker-dealer? Should you be?

USA - April 11 2013 On April 5, 2013, the SEC published certain remarks of David W. Blass, Chief Counsel, Division of Trading and Markets, made before the Trading and...

Michael B. Gray.

SEC identifies investment adviser, investment company examination priorities for 2013

USA - February 26 2013 On Feb. 21, 2013, the SEC’s National Examination Program (“NEP”) published its examination priorities for 2013. This annual memorandum informs...