Bingham McCutchen LLP Boston, MA Document Search Results (36)
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|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.
|SEC Staff Issues Proxy Voting Guidance|
Abigail Bertumen, Lea Anne Copenhefer, Barry N. Hurwitz, Christopher D. Menconi; Bingham McCutchen LLP;
July 25, 2014, previously published on July 11, 2014Just before the July 4th holiday, the SEC’s Division of Investment Management and Division of Corporate Finance issued guidance on proxy voting. The guidance, which is a staff bulletin in the form of a Q&A, is the next chapter in an ongoing discussion about how investment advisers satisfy...
|SEC Brings First Whistleblower Anti-Retaliation Claim Under the Dodd-Frank Act|
Matthew T. Bohenek, Steven W. Hansen; Bingham McCutchen LLP;
July 25, 2014, previously published on July 10, 2014Dealing with a whistleblower who remains an employee after going to the Government has always been something like traversing a mine field. When the Securities and Exchange Commission (“SEC”) adopted Rule 21F-2, defining a “whistleblower” and making a violation of the...
|SEC Orders a Pilot Program on Tick Sizes to Study Trading Behavior|
Russell M. Fecteau; Bingham McCutchen LLP;
July 25, 2014, previously published on July 15, 2014On June 24, 2014, the Securities and Exchange Commission (SEC) ordered national stock exchanges and the Financial Industry Regulatory Authority (FINRA) to craft a yearlong pilot program that requires specific stocks (“Pilot Securities”) to trade in five-cent increments rather than...
|Andrew Ceresney: 2014 Enforcement Accomplishments and Priorities Relating to Financial Services Firms|
Amy Natterson Kroll, Elizabeth A. Marino; Bingham McCutchen LLP;
July 14, 2014, previously published on June 17, 2014Andrew Ceresney, Director, Division of Enforcement (the “Division”), Securities and Exchange Commission (“Commission”), recently spoke at Compliance Week 2014 regarding the Division’s accomplishments over the past year and its priorities for the remainder of 2014.1 Of...
|FINRA Provides Dark Pool Trading Data|
Russell M. Fecteau, Elizabeth A. Marino; Bingham McCutchen LLP;
June 17, 2014, previously published on June 11, 2014On June 2, 2014, and pursuant to FINRA Rule 4552, the Financial Industry Regulatory Authority Inc. (“FINRA”) began publishing trading data attributable to alternative trading systems (“ATSs”), inclusive of trading data from “dark pools.” According to FINRA,...
|Five Takeaways About Cybersecurity From the OCIE Cybersecurity Risk Alert|
Laura E. Flores, Jason E. Glass, Michael R. Weissmann; Bingham McCutchen LLP;
April 25, 2014, previously published on April 21, 2014On April 15, 2014, SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing an initiative it is currently undertaking to assess cybersecurity preparedness in the securities industry. The Risk Alert includes a seven page appendix with 28...
|CFTC Regulation 1.35 Recordkeeping Requirements Set to Become Effective on May 1, 2014|
Daniel N. Budofsky; Bingham McCutchen LLP;
April 16, 2014, previously published on April 11, 2014On May 1, 2014, no-action relief from compliance with U.S. Commodity Futures Trading Commission (“CFTC”) Regulation 1.35 will come to an end. With the expiration of this no-action period, certain market participants will be subject to substantial recordkeeping requirements, including...