Document(s) published by this organization: 4
|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...
|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...
|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...
|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...