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Bingham McCutchen LLP Boston, MA Document Search Results (30)

 

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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 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...

 

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...

 

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....

 

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...

 

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...

 

HTMLSecond Circuit Defines ‘Customer’ Under FINRA Arbitration Rules
David C. Boch, Michael C. Moran; Bingham McCutchen LLP;
Legal Alert/Article
August 22, 2014, previously published on August 15, 2014
The 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...

 

HTMLAnti-Money Laundering Customer Due Diligence
K. Michael Carlton, Barry N. Hurwitz, Andrew B. Kales, W. John McGuire, Carl A. Valenstein; Bingham McCutchen LLP;
Legal Alert/Article
August 11, 2014, previously published on August 8, 2014
On 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...

 

HTMLDelaware 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;
Legal Alert/Article
August 8, 2014, previously published on August 1, 2014
Over 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...

 

HTMLSEC Adopts Money Market Fund Reforms
Lea Anne Copenhefer, Barry N. Hurwitz, Roger P. Joseph, Christopher D. Menconi, Mari Wilson; Bingham McCutchen LLP;
Legal Alert/Article
August 2, 2014, previously published on July 23, 2014
The 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.

 


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