Document(s) published by this organization: 17
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|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 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...
|Seventh Circuit Expands Apportionment Defense, Potentially Limiting Joint and Several CERCLA Liability|
Jeremy Esterkin, Denise G. Fellers, Mae Kieng Hau, Rick R. Rothman; Bingham McCutchen LLP;
November 10, 2014, previously published on October 15, 2014The Seventh Circuit issued two significant decisions relating to the cleanup of the Lower Fox River and Green Bay Superfund Site (the “Site”) on September 25, 2014. In the first, NCR Corp. v. George A. Whiting Paper Co., No. 13-2447 (7th Cir. Sept. 25, 2014), the Court reaffirmed that a...
|Recent Questionnaire from the Kanto Local Finance Bureau|
Tomoko Fuminaga, Rie Nitta, Yoshiyuki Omori, Christopher P. Wells, Koji Yamamoto; Bingham McCutchen Murase Sakai Mimura Aizawa Foreign Law Joint Enterprise;
November 10, 2014, previously published on October 24, 2014We understand that on or around October 22, 2014, all financial instruments business operators registered with the Kanto Local Finance Bureau of Japan (the “KLFB”) to engage in an “investment advisory and agency business” (an “IAA”) received a questionnaire from...
|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...
|Margin Trading and Short Selling on Shanghai Stock Exchange by Foreign Investors|
Fred Chang, Yan Li, Jin Wang; Bingham McCutchen LLP;
October 6, 2014, previously published on September 30, 2014Following the establishment of the “Shanghai-Hong Kong Stock Connect Program” (“Program”) this past June, the Shanghai Stock Exchange (“SSE”) issued two rules on September 26, 2014, introducing certain changes to the Program, the most significant of which is the...
|As World Leaders Gather at the UN Climate Summit, the Aviation Sector Could Provide a Template for International Climate Progress|
John P. Schmitz, Martina Simpkins; Bingham McCutchen LLP;
September 25, 2014, previously published on September 23, 2014More than 120 heads of state, including President Barack Obama, gathered for the Climate Summit hosted by UN Secretary-General Ban Ki-moon in New York City on September 23. Financial pledges to the Green Climate Fund and statements regarding the leaders’ commitments to reach agreement on a...
|FCC Sets Deadline for and Narrows Scope of Special Access Mandatory Data Collection|
Russell M. Blau, Joshua M. Bobeck, Eric J. Branfman, Tamar E. Finn, Andrew D. Lipman; Bingham McCutchen LLP;
September 25, 2014, previously published on September 18, 2014On Monday, September 15, 2014, the FCC’s Wireline Competition Bureau (“WCB”) issued a Reconsideration Order revising the mandatory data collection in the special access proceeding based on concerns raised by the Office of Management and Budget (“OMB”). In this Order,...
|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...