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 […]
The SEC has sent the FINRA propose rules for capital acquisition brokers out for comment. Comments are due on April 13, 2016. As you may remember these rules are the outcome of the No-Action letter previously issued by the SEC relating to the registration of a finder as a broker-dealer. Under the proposed rules capital […]
As it does every year FINRA has published its Regulatory and Examination Priorities Letter. This year it is focused on three broad issues: Culture, Conflict of Interest and Ethics Supervision, Risk Management and Control Liquidity FINRA and its predecessor entities have always talked about “firm culture”. But this year they have given it a definition: […]
Davison-Lawblog is back. As before I will provide practical legal and regulatory solutions to the ever growing regulatory issues that arise for broker-dealers and financial service firms. I am also interested in engaging with you and hope you will leave your comments.