Bingham McCutchen LLP Boston, MA Document Search Results (14)
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|FINRA Solicits Comment on Proposed Rule to Implement CARDS|
Yevedzo R. Chitiga, Russell M. Fecteau, Michael R. Weissmann; Bingham McCutchen LLP;
November 10, 2014, previously published on October 13, 2014FINRA is seeking comments on a proposed rule to implement the Comprehensive Automated Risk Data System (“CARDS”). FINRA published a CARDS concept proposal on December 23, 2013 (the “Concept Proposal”), to which it received approximately 800 comment letters. According to...
|Microcap Securities: OCIE Issues Risk Alert Related to Broker-Dealer Controls Regarding Customer Sales|
Amy Natterson Kroll, Elizabeth A. Marino, Michael R. Weissmann; Bingham McCutchen LLP;
November 10, 2014, previously published on October 17, 2014On 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...
|FINRA Requests Comments on Revised Proposal to Adopt Rule Mandating Quarterly Delivery of Customer Account Statements|
Saia M. Smith, Michael R. Weissmann; Bingham McCutchen LLP;
October 6, 2014, previously published on September 26, 2014On September 16, 2014, the Financial Industry Regulatory Authority, Inc. (“FINRA”) requested comments on a revised proposal to adopt a consolidated rule regarding delivery of customer account statements. FINRA Rule 2231 would bring NASD Rule 2340 (Customer Account Statements) and NYSE...
|Limited Partners of Investment Managers may be Subject to Self-Employment Taxes|
Donald-Bruce Abrams, Charles R. Bogle, Anthony J. Carbone, Thomas Gray; Bingham McCutchen LLP;
September 25, 2014, previously published on September 15, 2014On September 5, 2014, the Internal Revenue Service (“IRS”) issued Chief Counsel Advice 201436049 (the “CCA”), concluding that members of an investment manager were subject to self-employment (“SE”) taxes with respect to their earnings from the investment manager....
|CFTC Issues JOBS Act Exemptive Relief: Resolves Issues Surrounding the Use of General Solicitation by Private Funds|
Michelle R. Cirillo, Derek Wolfgruber; Bingham McCutchen LLP;
September 25, 2014, previously published on September 15, 2014On September 9, 2014, the Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealer and Intermediary Oversight (the “Division”) issued a letter which provides exemptive relief to commodity pool operators (“CPOs”) of private funds from the...
|SEC Announces Enforcement Initiative Against Corporate Insiders for Violations of Reporting Requirements|
Daniel N. Budofsky, Barry N. Hurwitz, David I. Miller; Bingham McCutchen LLP;
September 25, 2014, previously published on September 15, 2014On September 10, 2014, the Securities and Exchange Commission (SEC) announced a series of enforcement actions against 28 officers, directors, and major shareholders — so-called “insiders” — for failure to file timely reports under Sections 16(a), 13(d) and 13(g) of the...
|Second Circuit Defines ‘Customer’ Under FINRA Arbitration Rules|
David C. Boch, Michael C. Moran; Bingham McCutchen LLP;
August 22, 2014, previously published on August 15, 2014The U.S. Court of Appeals for the Second Circuit has provided a measure of clarity in limiting the definition of a “customer” who may bring a FINRA arbitration under FINRA Rule 12200. The decision is significant for those member firms that provide a broad array of financial services...
|Anti-Money Laundering Customer Due Diligence|
K. Michael Carlton, Barry N. Hurwitz, Andrew B. Kales, W. John McGuire, Carl A. Valenstein; Bingham McCutchen LLP;
August 11, 2014, previously published on August 8, 2014On July 30, 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed regulations seeking to clarify and strengthen the customer due diligence obligations of certain types of financial institutions aimed at preventing money laundering in the...
|Delaware Supreme Court Allows Plaintiff Shareholders to ‘Invade’ Corporation’s Attorney-Client Privilege for Good Cause|
Michael D. Blanchard, Christopher M. Wasil, P. Sabin Willett; Bingham McCutchen LLP;
August 8, 2014, previously published on August 1, 2014Over forty years ago, in Garner v. Wofinbarger, 430 F.2d 1039 (5th Cir. 1970), the Fifth Circuit held that, with a showing of good cause, a shareholder investigating potential fiduciary breaches could overcome the attorney-client privilege for internal corporate documents. In Delaware, several...
|SEC Adopts Money Market Fund Reforms|
Lea Anne Copenhefer, Barry N. Hurwitz, Roger P. Joseph, Christopher D. Menconi, Mari Wilson; Bingham McCutchen LLP;
August 2, 2014, previously published on July 23, 2014The U.S. Securities and Exchange Commission voted 3-2 today to adopt significant changes to the regulation of money market funds in an effort to minimize the potential for a systemic “run” on money market funds like the one experienced in 2008.