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Municipal Securities Regulation and Enforcement - 2024 Mid-Year Review

In the first half of 2024, the Financial Industry Regulatory Authority (FINRA) issued several fines and suspensions against participants in the municipal market, including for violations of its registration, reporting,...more

SEC Increases Scrutiny of Whistleblower Protections

Summary - The Securities and Exchange Commission (SEC) has recently announced settlements with a number of companies whose separation agreements or internal policies the SEC viewed as impeding employees’ participation in the...more

Second SEC NFT-Enforcement Action Finds Another NFT to Be a Security

Summary - The SEC’s pursuit of the crypto industry continues with its second-ever settlement of a non-fungible token (NFT) enforcement action. The SEC settled with Stoner Cats 2 LLC (SC2), which sought to finance an...more

SEC Finds NFT to Be a Security in Landmark Action

Summary - The SEC’s focus on the crypto industry expanded this week to include non-fungible tokens (NFTs). In its first NFT-enforcement action, the SEC settled with Impact Theory, a media and entertainment company, over...more

SEC Nears First Settlement With a Credit Rating Agency in Off-Channel Communications Sweep

Summary - The Securities and Exchange Commission (SEC) is reportedly nearing a settlement with a nationally recognized statistical rating organization (NRSRO) over its failure to preserve certain credit-ratings...more

Terraform Versus Ripple – Courts Split on Whether Cryptocurrency Is a Security

Summary - Just when it looked like a victory for the crypto industry in SEC v. Ripple, a mere two weeks later, a different judge in the Southern District of New York disagreed with Ripple’s holding, introducing greater...more

The SEC’s Recent Personal Device Settlements Shed Light on the Question of Self-Reporting

Summary - Two more broker-dealers became the latest financial institutions to settle with the SEC for failing to maintain and preserve electronic communications. What distinguishes these settlements from the 17 prior...more

FASB Proposes New Crypto Accounting Standards, SEC Alert Reinforces ‘Securities’ Enforcement Authority

Summary - The past week was a busy one in the cryptocurrency sphere: The Financial Accounting Standards Board (FASB) proposed new standards for crypto assets, and the SEC released an alert urging investors to remain...more

Ontrak Indictment Showcases DOJ-SEC Collaboration

Summary - The recently unsealed indictment of health care company Ontrak for insider trading marks the first criminal prosecution alleging an executive’s fraudulent use of a 10b5-1 trading plan to facilitate unlawful...more

Insider Trading Concerns Spur SEC to Propose Amending Rule 10b5-1

Summary - A proposal by the Securities and Exchange Commission to amend Rule 10b5-1, as well as recent enforcement activity relating to these plans, suggest that the SEC is concerned that the rule has been used as cover...more

SEC Adopts Executive Compensation ‘Clawback’ Rules

Summary - The SEC this week adopted new rules that will require publicly traded companies to “claw back” incentive-based executive compensation that a company awarded to the executive based on materially misreported...more

SEC Amends Whistleblower Program Rules

Summary - Section 21F of the Securities Exchange Act of 1934 (the Exchange Act) governs the Securities and Exchange Commission (the SEC or the Commission) whistleblower program, which pays awards to eligible whistleblowers...more

Private Funds, ‘Greenwashing,’ and Crypto-Assets are Among SEC’s Top Examination Priorities in 2022

Summary - The U.S. Securities and Exchange Commission this week published its 2022 Examination Priorities report. This year, the SEC’s Division of Examinations plans to prioritize scrutiny of Private Funds; Environmental,...more

The SEC FY 2023 Budget Request Predicts Increased Enforcement Activities

Summary - The Securities and Exchange Commission (SEC) this week released its annual Congressional Budget Justification. The agency is seeking a budget of $2.15 billion for FY 2023, which is almost $240 million more than...more

SEC and DOJ Target Insider Trading on the Dark Web

The U.S. Securities and Exchange Commission (SEC) and the U.S. Department of Justice (DOJ) brought actions against SpaceX engineer James Roland Jones for selling insider information on what’s known as the dark web....more

SEC Announces Enforcement Task Force Focused on Climate and ESG Issues

Today, the SEC sent a very clear signal about one of its chief enforcement priorities by announcing the creation of a Climate and ESG Task Force within the Division of Enforcement. ESG stands for Environmental, Social, and...more

SEC Announces First Enforcement Action Against Public Company for Misleading COVID-19 Disclosures

Summary - The Securities and Exchange Commission (SEC) announced today that it has settled its case against The Cheesecake Factory charging the national restaurant chain with providing misleading disclosures in filings—the...more

SEC and DOJ’s Antitrust Division Formalize Interagency Cooperation With Historic Memorandum of Understanding

In an historic move this week, the Securities and Exchange Commission (SEC) and the Antitrust Division of the Department of Justice (DOJ) executed the first-ever memorandum of understanding (MOU) between the two agencies. ...more

Financial Disclosures in the COVID-19 Era for REITs and other Public Companies Relating to Real Estate Assets and Liabilities

The stock markets’ volatility in the era of the COVID-19 pandemic is one of the virus’ largest impacts. With that in mind, the SEC recently made clear that timely disclosure of significant financial and non-financial issues...more

SEC Signals New Phase of Regulation FD Enforcement

The United States Securities and Exchange Commission (SEC) announced yesterday, August 20, 2019, that it charged TherapeuticsMD, Inc., a pharmaceutical company headquartered in Boca Raton, Florida, with violations of...more

Has the SEC Lost Home Court Advantage?

For years, the Securities and Exchange Commission (SEC) has aggressively utilized its own administrative law judges to adjudicate enforcement proceedings, prompting critics to argue that this strategy gives the SEC a decided...more

SEC Targets AML as Exam Priority

Wednesday, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2018 examination priorities, released in order to “improve compliance, prevent fraud, monitor risk, and inform policy.” ...more

SEC and CFTC Issue Joint Statement on Virtual Currency Enforcement Actions

The following joint statement was issued this last week from the Enforcement Directors of the Securities Exchange Commission and Commodity Futures Trading Commission...more

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