The Securities and Exchange Commission (SEC) has proposed an exemption from broker-dealer registration requirements for certain “finders” who raise capital for issuers in private offerings and receive transaction-based compensation for doing so (i.e., a “success fee”).
Continue Reading SEC Proposes Allowing ‘Finders’ to Raise Capital Without Registering as Broker-Dealers
Investment
SEC Proposes Rules to Modernize and Enhance Information Reported by Investment Companies and Investment Advisers
On May 20, the Securities Exchange Commission proposed changes to rules affecting the reporting and disclosure obligations of registered investment companies and advisers.
Continue Reading SEC Proposes Rules to Modernize and Enhance Information Reported by Investment Companies and Investment Advisers
FINRA Issues Interpretive Guidance on Use of Back Tested Index Data by ETPs
Co-authored by Gregory E. Xethalis, Kathleen H. Moriarty and Marybeth Sorady.
On April 22, the Financial Industry Regulatory Authority, Inc. issued to ALPS Distributors, Inc. interpretive guidance with respect to FINRA Rule 2210(d) and the use of hypothetical back tested index performance information, which FINRA refers to as pre-inception index performance (PIP) data. …
SEC Adopts Revised Net Worth Standard for Accredited Investors
By Robert L. Kohl on
Co-authored by James B. Anderson.
On December 21, the Securities and Exchange Commission adopted an amendment to the accredited investor net worth standard under Regulation D of the Securities Act of 1933, as amended, to exclude the value of an individual’s primary residence from the $1 million net worth calculations used to determine whether such individual is an “accredited investor” qualified to invest in certain unregistered securities offerings. The amendment conforms the SEC’s definition of an “accredited investor” to the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).Continue Reading SEC Adopts Revised Net Worth Standard for Accredited Investors