Guidance

Small Entity Compliance Guide

On November 7th, the SEC published guidance to smaller entities on recent changes to SEC rules regarding credit rating agencies and asset-backed securities. The guidance summarizes amendments to Securities Exchange Act Rule 17g-1, the instructions for Exhibit 1 to Form NRSRO, Rule 17g-2, Rule 17g-3, Rule 17g-5, Rule 17g-7, and Form ABS-15G; and newly added Securities Exchange Act Rule 17g-8, Rule 17g-9, Rule 17g-10, Form ABS Due Diligence-15E, and Rule 15Ga-2., providers of due diligence services to asset-backed securities, issuers and underwriters. Small Entity Compliance Guide.

Other Developments

Open Meeting

The SEC will hold an open meeting on November 19, 2014 to consider whether to adopt Regulation Systems Compliance and Integrity under the Securities Exchange Act of 1934 and conforming amendments to Regulation ATS. Sunshine Act Notice.

SEC Small Business Forum Agenda and JOBS Act Session

The SEC published the agenda for its November 20, 2014 Government-Business Forum on Small Business Capital Formation. SEC Small Business Forum Press Release. On November 19, 2014, a day prior to this year’s Small Business Forum, the SEC will partner with the Small Business Administration to present information on the Jumpstart Our Business Startups (“JOBS”) Act. SEC JOBS Act Press Release.

Tick Test Critics

On November 11th, Bloomberg discussed the criticism some have levelled at the proposed tick test pilot that would widen the increments for trading the shares of certain smaller companies. Tick Test Critics.

Rulemaking Agenda

On November 10th, Reuters noted SEC Chair Mary Jo White’s rulemaking agendaAmong other things, White hopes to address market structure issues in the coming months. Agenda.

Municipal Focus

On November 10th, Bloomberg reported Andrew Ceresney, Director of the Division of Enforcement, said that his office intends to seek individual liability against those who violate municipal securities rules. Individual Focus.