.... Licensed re-use rights only United States U.S. Securities and Exchange Commission (SEC) Disgorgement Kokesh Injunction Lifetime Bar 3. Kokesh v. S.E.C., 137 S. Ct. 1635, 1642 (2017), at 1643, at 1642 (internal citations and quotation marks omitted). 4...

..., 2004) www.sec.gov/divisions/investment/noaction/ica030104.htm United States Securities and Exchange Commission (SEC) Advertising and marketing materials Advertising rule Compliance policies and procedures Touting Initiative The Securities and Exchange Commission’s (SEC’s) Office...

...” under the Custody Rule. United States US Securities and Exchange Commission (SEC) Custody Rule Form PF Participating affiliate Robo-adviser It appears that advisers relying on the Unibanco letters generally maintain internal records of the representations and undertakings...

... their firms’ operations address the guidance. Originality/value Practical advice from experienced securities regulatory lawyers. Amy Ward Pershkow can be contacted at: apershkow@mayerbrown.com © Mayer Brown. 2017 Mayer Brown Licensed re-use rights only United States Securities...

... in an incorrect disclosure.” © Debevoise & Plimpton LLP 2016 Emerald Group Publishing Limited Licensed re-use rights only United States Enforcement actions Securities and Exchange Commission Policies and procedures Financial reporting and disclosure Yates memorandum Set against...

...V. Gerard Comizio; Behnam Dayanim; Laura Bain Purpose To provide financial institutions an overview of the developments in cybersecurity regulation of financial institutions during 2015 by the United States, the United Kingdom, and the European Union, as well as guidance for developing effective...

.... Originality/value – Detailed, informative case study. Majed Muhtaseb can be contacted at: majedcfa@gmail.com © Emerald Group Publishing Limited 2015 United States Securities and Exchange Commission (SEC) Fraud Hedge fund Investment manager Hedge fund assets under management...

... at: richard.parrino@hogallovells.com © Authors 2015 United States Securities Act of 1933 Supreme Court Disclosure in securities offerings Section 11 liability Securities regulation On March 24, 2015, the US Supreme Court issued its much-anticipated decision in Omnicare, Inc. v...

... derivatives/structured products and bankruptcy/commercial restructuring lawyers. United States Bankruptcy International swaps and derivatives association (ISDA) Safe harbor On May 30, 2014, hedge fund Moore Capital (Moore) brought suit against the Lehman Brothers bankruptcy estate (Lehman...

... to a particular taxpayer can be so counterintuitive that disbelief on being advised that a form must be filed, and the draconian penalties for noncompliance is a common response. Roger Lorence can be contacted at: lorencelaw@gmail.com © Emerald Group Publishing Limited 2015 United States...

... sponsors use in allocating expenses, both between private equity sponsors and the funds they manage, as well as among commonly managed private funds[ 1 ]. Kenneth Berman can be contacted at: kjberman@debevoise.com © Authors 2015 United States Securities and Exchange Commission (SEC...

... United States Securities and Exchange Commission (SEC) Investment advisers Proxy advisory firms Proxy system Staff Legal Bulletin On June 30, the SEC released a 7-page Staff Legal Bulletin, in the form of 13 Q&A’s, summarizing the results of a comprehensive review of the proxy system...

... against them, which amounted to a total of $2.6 million in monetary penalties for the 33 respondents who settled the charges. United States Securities and Exchange Commission (SEC) Securities Exchange Act of 1934 Section 13 filings Section 16 reports Securities regulation © Authors 2015...

.... Originality/value – Practical guidance from experienced tax controversy lawyers. Miriam Fisher can be contacted at: miriam.fisher@lw.com © Authors 2015 United States Foreign account tax compliance act (FATCA) Enforcement Compliance Financial fraud enforcement task force Fraud...

.... The Final Rules are intended to enhance these protections and to specifically address the customer and systemic risks posed by the types of events that surrounded the recent insolvencies of MF Global, Inc. and Peregrine Financial Group, Inc. United States Commodity Futures Trading Commission (CFTC...

... structure remains appropriate for customers, taking into account the services provided, cost and customer preferences. Daniel A. Nathan can be contacted at: dnathan@mofo.com © Authors 2014 United States Securities and Exchange Commission (SEC) Double charging Fee-based accounts...

... to avoid a loss of $750,000 [11] . More than five years later, on October 16, 2013, a jury acquitted him on all charges [12] . Charlie Kruly can be contacted at: charles.kruly@sutherland.com © Authors 2014 United States Securities and Exchange Commission (SEC) Admission...

... calculus for many corporations and individuals who are negotiating with the SEC. United States Securities and exchange commission Admission of wrongdoing Admission of misconduct No admit No deny settlement The Securities and Exchange Commission (SEC) has changed its policy concerning...

... Advisers Act Section 203(b)(3), which provided an exemption for advisors that had 14 or fewer clients – were required to register as RIAs for the first time. Robert P. Bramnik can be contacted at: RPBramnik@duanemorris.com © Authors 2014 United States Securities and Exchange Commission...

... can be contacted at: Russell.Sacks@shearman.com © Authors 2014 The rule implements a number of other rules impacting IPO allocation practices in addition to the “spinning” prohibition. Those regulations include: United States Securities and Exchange Commission (SEC) Allocation...