SEC Commissioner Daniel Gallagher, in a speech on June 25, 2015, said that a perceived trend by the SEC toward “strict liability” for chief compliance officers (CCOs) is “sending a troubling message.”
Relying on a data-driven statistical analysis conducted by the Division of Economic and Risk Analysis (DERA), the SEC recently commenced administrative proceedings against an investment advisor, Welhouse & Associates, Inc., and its principal, charging them with improperly allocating profitable options trades to the principal’s own accounts while allocating unprofitable trades to the firm’s clients.
The Securities and Exchange Commission has issued new rules, termed Regulation A+, which were promulgated under Section 401 of the 2012 Jumpstart Our Business Startups Act, also known as the JOBS Act, which expand upon the previous Regulation A.
The Securities and Exchange Commission has announced new Lesbian, Gay, Bisexual, and Transgender (LGBT) inclusive interpretations of the terms “spouse” and “marriage.”
Recent SEC enforcement actions suggest that being a CCO is not all that it’s cracked up to be; the SEC recently sanctioned two CCOs.
On June 23, 2015, the Securities and Exchange Commission (SEC) issued a press release in connection with charging two firms that unlawfully brokered more than $79 million of EB-5 investments to more than 150 investors seeking U.S. residency under the EB-5 Investor Visa Program.
Recently, a colleague at lunch asked me if I was familiar with a case involving the constitutionality of Securities and Exchange Commission administrative law judge proceedings.
If there is any question that the SEC is focused on elder investor issues, look no further than its recent program announcement.
The D&O Diary was in Palo Alto, California this week for the annual Directors’ College at the Stanford Law School (depicted to the left).