Legal Alerts

  1. Recent Questionnaire from the Kanto Local Finance Bureau

    Oct. 24, 2014 We understand that on or around October 22, 2014, all financial instruments business operators registered with the Kanto Local Finance Bureau of Japan (the “KLFB”) to engage in an “investment advisory and agency business” (an “IAA”) received a questionnaire from the KLFB by e-mai... more >
  2. SEC Announces Intention to Deny Proposals for Non-Transparent ETFs

    Oct. 23, 2014 In a highly unusual regulatory action, the Securities and Exchange Commission (“SEC”) has stated in two formal notices that it intends to deny proposals that would permit an actively-managed exchange traded fund to operate without disclosing its portfolio holdings on a daily basi... more >
  3. Microcap Securities: OCIE Issues Risk Alert Related to Broker-Dealer Controls Regarding Customer Sales

    Oct. 17, 2014 On October 9, 2014, the Securities and Exchange Commission’s (“Commission”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert reporting on significant deficiencies it found in its sweep of 22 broker-dealers that regularly sell microcap securities (“Ri... more >
  4. Seventh Circuit Expands Apportionment Defense, Potentially Limiting Joint and Several CERCLA Liability

    Oct. 15, 2014 The Seventh Circuit issued two significant decisions relating to the cleanup of the Lower Fox River and Green Bay Superfund Site (the “Site”) on September 25, 2014. In the first, NCR Corp. v. George A. Whiting Paper Co., No. 13-2447 (7th Cir. Sept. 25, 2014), the Court reaffirmed... more >
  5. FINRA Solicits Comment on Proposed Rule to Implement CARDS

    Oct. 13, 2014 FINRA is seeking comments on a proposed rule to implement the Comprehensive Automated Risk Data System (“CARDS”).1 FINRA published a CARDS concept proposal on December 23, 2013 (the “Concept Proposal”),2 to which it received approximately 800 comment letters.3 According to FINRA,... more >
  6. The 2014 Bingham Presents Event Offers Valuable Guidance on the SEC’s Enforcement Priorities

    Oct. 7, 2014 On Monday, September 15, 2014, through its partnership with the SEC Historical Society, Bingham held its sixth annual Bingham Presents event. The event featured a distinguished group of panelists who are all well versed in the topic of discussion, Current Issues in Broker-Dealer ... more >
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