The US Second Circuit this Wednesday narrowed the scope of "tippee" liability for insider trading, rejecting the "doctrinal novelty" of recent government prosecution theories. In United State v. Newman, Nos. 13-1837-cr c/w 13-1917-cr (2nd Cir. Dec. 10, 2014), the Court reversed the insider-trading and conspiracy convictions of two portfolio managers. They were downstream tippees, who traded on information passed along from corporate insiders to securities analysts and, ultimately, Newman and Chaisson. The Court of Appeals reversed, because the jury instructions had ...

Posted in: SEC
The SEC this week issued cease-and-desist orders against eight auditors, fining them $140,000 collectively, for violating auditor independence rules by preparing the very broker-dealer financials they were to audit. Broker-dealer auditors are bound by auditor-independence criteria established under Reg. S-X. By using BD-provided documents to prepare the client's financial statements, the sanctioned firms "essentially put themselves in the position of auditing their own work," said the SEC's release, here. The Release is another in a growing trend in which Enforcement ...
Posted in: SEC
Following the final 2014 meeting of the Board of Governors last week, FINRA announced its proposal to increase fees associated with cancelling or postponing an arbitration hearing. In a December 4, 2014 email to firms, FINRA reported that the Board proposed to amend Rules 12601 and 13601 of the Code of Arbitration Procedure to extend the time required to give notice of an arbitration cancellation and increase cancellation fees. Under the proposed rule, if a party requests and receives a postponement or cancellation less than 10 days from a scheduling hearing, it would have to pay an ...
Posted in: FINRA

The Alabama Court of Civil Appeals released a slip opinion on May 16, 2014 addressing enforcement of a nonsolicitation agreement against a licensed securities broker. See G.L.S. & Associates, Inc., and G.L. Smith & Associates, Inc. v. Keith Rogers, No. 2130322 (Ala. Civ. App. May 16, 2014) (Slip Opinion). The defendant (Rogers) worked for a securities firm (GLSA) and had an employment agreement that contained a nonsolicitation provision which prohibited Rogers from soliciting GLSA's clients for a period of two years after termination of employment. Rogers resigned from his ...

Earlier this month, the SEC used a "control-person" charge in a settled action against an elected municipal official in connection with municipal bond offering. Enforcement touted that "first" on the Monday after: "An enforcement model with no penalties was not sustainable," Enforcement Director Andrew Ceresney, said during a panel discussion. "The most effective deterrent is individual liability, so we need to be focused on that." (at SIFMA Monday, Nov. 10 as reported Bloomberg) But the SEC's releases, and press coverage of remarks in the days after, did not disclose ...
Posted in: MSRB, SEC
Last Friday, FINRA proposed pay-to-play prohibitions that parallel and implement similar Investment Adviser Act provisions in Rule 206(4)-5. That IA Rule prohibits investment advisers from paying third-parties to solicit government-entity advisory clients unless the solicitor is a "regulated person" subject to similar pay-to-play provisions. The SEC adopted the IA Rule in July 2010, but this particular requirement wasn't triggered until the Commission's adoption of the Municipal Advisor Rule, which became effective this past July 1. FINRA's proposed Rules are modeled ...
Posted in: FINRA

In an unusual three-page concurrence to a November 10 cert denial, Justice Scalia (joined by Justice Thomas) virtually called for a case that would subject the SEC's insider-trading interpretations to scrutiny. Because courts owe no deference to a prosecutor's interpretation of a criminal law, asked Scalia, then why should they owe Chevron deference to an executive agency's interpretation of a law [like '34 Act § 10(b)] that's enforced both criminally and administratively? Scalia also criticized deferring to the SEC's expansive insider-trading theory in the case as turning ...

Posted in: SEC

The American Commodity Futures Trading Commission (CFTC), British Financial Conduct Authority (FCA), and Swiss Financial Market Supervisory Authority (FINMA) announced fines of $3.4 billion against five global banks on Wednesday, November 12th, 2014. The five banks were UBS ($799 million), Citigroup ($668 million), JP Morgan Chase ($662 million), the Royal Bank of Scotland ($634 million), and HSBC ($618 million). Of the total fine, $1.77 billion came from the FCA, $1.475 billion came from the CFTC, and $138 million came from FINMA. All of the banks had set aside funds as reserves ...

The SEC continues to ramp up its Enforcement efforts in the municipal-securities realm. The agency announced a series of settled actions on November 6. First "Control Person" Charge Against Issuer Officials The Commission announced a settled administrative proceeding against municipal issuer Allen Park, Michigan and settlements in federal-court actions against the City's former Mayor and City Administrator. The SEC charged that offering documents for two bond issues knowingly painted too rosy a picture for a $146 million film-studio project, which had been all but ...

Posted in: MSRB, SEC
Speaking at PLI event November 5, US District Judge Jed Rakoff joined the chorus criticizing the SEC's expanded use of its administrative forum. Rakoff acknowledged the trend's potential unfairness to Respondents, and voiced his concern that the move might stifle "the impartial development of the law in an area of immense practice importance." He also compared the Commission's 100% success rate in administrative cases during FYE September 30, 2014 with its 61% win rate in federal court over the same time. Rakoff's remarks were reported by Law360, and by Reuters, here. We've been ...
Posted in: SEC
Burr
Jump to Page
Arrow icon Top

Contact Us

Cookie Preference Center

Necessary Cookies

Always Active

Necessary cookies enable core functionality such as security, network management, and accessibility. These cookies may only be disabled by changing your browser settings, but this may affect how the website functions.

Analytical Cookies

Analytical cookies help us improve our website by collecting and reporting information on its usage. We access and process information from these cookies at an aggregate level.