On Sept. 12, 2024, the Commodity Futures Trading Commission (CFTC) took another step toward limiting the availability and scope of relief provided by CFTC Regulation 4.7 (Reg. 4.7) under the
Continue Reading CFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’SEC Cracks Down on Marketing Rule Violations: Takeaways for Investment Advisers
On Aug. 9, 2024, the Securities and Exchange Commission initiated administrative and cease-and-desist proceedings against a U.S. registered investment adviser (the Adviser). This action resulted from the Adviser’s failure to…
Continue Reading SEC Cracks Down on Marketing Rule Violations: Takeaways for Investment AdvisersSEC Adopts Cybersecurity Amendments to Regulation S-P
On May 16, 2024, the U.S. Securities and Exchange Commission finalized amendments to Regulation S-P (the Amendments) that largely adopt the proposed amendments the SEC issued in 2023. As discussed…
Continue Reading SEC Adopts Cybersecurity Amendments to Regulation S-PSEC Clarifies Confusion Concerning Cybersecurity Incident Reporting
On May 21, 2024, U.S. Securities and Exchange Commission Director of the Division of Corporation Finance Erik Gerding issued a statement clarifying when the SEC expects companies to disclose a…
Continue Reading SEC Clarifies Confusion Concerning Cybersecurity Incident ReportingSEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents
On Sept. 6, 2023, the Securities and Exchange Commission’s Division of Examinations issued a Risk Alert detailing the Division’s examination selection process for SEC-registered investment advisers (Advisers). The Risk Alert…
Continue Reading SEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting DocumentsFINRA Approves Prometheum Ember Capital LLC to Operate as Special Purpose Broker-Dealer for Digital Assets
On May 17, 2023, Prometheum Ember Capital LLC (Prometheum Ember Capital), a subsidiary of Prometheum Inc., received approval from the Financial Industry Regulatory Authority (FINRA) to…
Continue Reading FINRA Approves Prometheum Ember Capital LLC to Operate as Special Purpose Broker-Dealer for Digital AssetsAre Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC Views
A holding subjecting Term Loan Bs to securities regulation would have a profound effect on the $1.4 trillion market for syndicated term loans and on financial institutions at a time of limited liquidity. …
Continue Reading Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC Views
CFPB And FTC Take Their Place As Powerful Crypto Cops
Crypto-asset businesses, particularly those offering crypto lending, non-fungible tokens, or digital wallet/payments products — which are already facing intense scrutiny from the SEC, CFTC, U.S. Department of Justice and U.S.
Continue Reading CFPB And FTC Take Their Place As Powerful Crypto CopsSEC Announces 2023 Examination Priorities
On Feb. 7, 2023, the Securities and Exchange Commission’s Division of Examinations announced its 2023 examination priorities. The announcement focuses on six different categories.
Continue reading the full GT Alert.
Continue Reading SEC Announces 2023 Examination PrioritiesSEC Proposes to Establish a New Best Execution Standard
On Dec. 14, 2022, Gary Gensler, Chair of the U.S. Securities and Exchange Commission (SEC), released a statement announcing a proposal to establish an SEC rule setting forth a best…
Continue Reading SEC Proposes to Establish a New Best Execution Standard