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Bingham McCutchen LLP Boston, MA Document Search Results (6)

 

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HTMLFINRA Solicits Comment on Proposed Rule to Implement CARDS
Yevedzo R. Chitiga, Russell M. Fecteau, Michael R. Weissmann; Bingham McCutchen LLP;
Legal Alert/Article
November 10, 2014, previously published on October 13, 2014
FINRA 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...

 

HTMLMicrocap 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;
Legal Alert/Article
November 10, 2014, previously published on October 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...

 

HTMLFINRA Requests Comments on Revised Proposal to Adopt Rule Mandating Quarterly Delivery of Customer Account Statements
Saia M. Smith, Michael R. Weissmann; Bingham McCutchen LLP;
Legal Alert/Article
October 6, 2014, previously published on September 26, 2014
On 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...

 

HTMLCFTC Issues JOBS Act Exemptive Relief: Resolves Issues Surrounding the Use of General Solicitation by Private Funds
Michelle R. Cirillo, Derek Wolfgruber; Bingham McCutchen LLP;
Legal Alert/Article
September 25, 2014, previously published on September 15, 2014
On 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...

 

HTMLSEC Announces Enforcement Initiative Against Corporate Insiders for Violations of Reporting Requirements
Daniel N. Budofsky, Barry N. Hurwitz, David I. Miller; Bingham McCutchen LLP;
Legal Alert/Article
September 25, 2014, previously published on September 15, 2014
On 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...

 

HTMLLimited 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;
Legal Alert/Article
September 25, 2014, previously published on September 15, 2014
On 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....