Michael R. Weissmann

Massachusetts Social Media Guidance: Interpretive Assistance for State-Registered Advisers Could Assist All in Grappling With Regulatory and Compliance Issues
W. Hardy Callcott,Jeffrey O. Himstreet,Paul M. Tyrrell,Michael R. Weissmann, February 20, 2012
On the heels of the social media alert issued by the staff of the Office of Compliance Inspections and Examinations (“OCIE”) of the Securities and Exchange Commission (“SEC”), the Massachusetts Securities Division (“Division”) has issued a report of its own...

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...