Happy New Year. I know it is a new year because FINRA has issued its Regulatory and Examination Priorities Letter. As with every yearly letter, it mostly covers the topics from the prior year. This year Operational and Financial Risks are clearly going to be a focus of examinations. Not surprising in the Sales Practice Section […]
As I open my new law office I decided it was time to relaunch my Blog/Website. So as of today I have a new look on my Blog. Come back as I write not only about broker-dealers, investment advisors and other financial institutions, but also about the practice of law for those entities. Also you […]
We are in the fourth full day of the administration of the 45th President. During the campaign he made a lot of promises. One was to reduce regulation. There were not a lot of specifics, but his nominations for cabinet positions would indicate that regulatory reduction is on the way. How is the reduction in […]
Every year at about this time, I like many other securities attorneys write a post about the examination priorities letters that are issued by the SEC and FINRA. From year to year the emphasis may change slightly but usually we know what the priorities will be. This year many thought the letters might change. FINRA […]
On October 17, 2016, the SEC approved the FINRA Capital Acquisition Brokers (“CAB”) rule set. As I reported a few months ago, these rules are intended for a limited group of entities that advise companies and private equity firms on capital raises and corporate transactions and act as placement agents for companies and private funds […]
The SEC has announced another enforcement action against a PE fund adviser. Four affiliated fund advisers of Apollo Global Management have agreed to settle an enforcement action for $52.7 million. The charges were misleading fund investors about fees and a loan agreement and failing to supervise a senior partner who charged personal expenses to the funds. […]
On June 1, 2016, the SEC issued an Administrative Order (SEC 34-77959, 40-4411) against BlackStreet Capital Management, LLC. At the highest level this was a disclosure case. I am however, going to focus on just one of the violations. The SEC found that: In connection with the acquisition and disposition of portfolio companies or their […]
