In January, the Securities and Exchange Commission issued a “no action letter” widely and wrongly interpreted as legalizing the role of unregistered broker/dealers as compensated M&A finders. The Securities Exchange Act of 1934 requires that broker/dealers register with the Financial ...Read More »
“Far from the madding crowd’s ignoble strife, their sober wishes never learned to stray.” — Thomas Gray, “Elegy Written in a Country Churchyard” (1751) In October, the Securities and Exchange Commission promulgated draft rules to implement “crowdfunding” in ...Read More »
Notwithstanding everything going on at the Securities and Exchange Commission these days, amending rules under Dodd-Frank and the JOBS Act, and bringing anti-fraud litigation, there nonetheless is one subject enjoying intense SEC focus: the Foreign Corrupt Practices Act.
Tagged with: Dec. 31 2012 issueRead More »
We are all aware of the substantial retrenchment of SEC enforcement mandated by the 2012 JOBS Act (“Act”), which contemplates crowd-funding and permits public advertising of certain “private placement” transactions (see my October column). But equally important is the impact ...
Tagged with: Nov. 30 2012 issueRead More »