David C. Boch

FINRA Amends Proposal Requiring Filings for Private Placements
David C. Boch,W. Hardy Callcott,James C. Magid,Michael R. Weissmann, February 2, 2012
On January 20, 2012, FINRA filed with the SEC a partial amendment to proposed FINRA Rule 5123 (Private Placement of Securities). This proposed rule would require broker-dealers to make filings with FINRA concerning most private placements they sell to investors. The most recent partial amendment...

OCIE’s Social Media Alert: Proceed With Caution, Maintain Required Records, and Adopt and Implement Robust Policies and Procedures
David C. Boch,W. Hardy Callcott,Jeffrey O. Himstreet,Paul M. Tyrrell,Michael R. Weissmann, January 13, 2012
On Jan. 4, 2012, the staff of the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission issued a National Examination Risk Alert concerning investment advisers’ use of social media. As with the previous adoption of email, Internet websites and...

FINRA Revises Proposed Communications With the Public Rule Yet Again—SEC Seeks Further Comment
David C. Boch,W. Hardy Callcott,Paul M. Tyrrell, January 4, 2012
The Financial Industry Regulatory Authority’s (“FINRA”) struggle to obtain the U.S. Securities and Exchange Commission’s (“SEC”) approval of its proposed revisions to its Communications with the Public Rules continues. On Dec. 22, 2011, FINRA filed with the SEC...