General Solicitation and General Advertising under Rule 502(c)
When it becomes effective on Sept. 23, 2013, the SEC’s new Rule 506(c) (PDF) will permit private-placement issuers to avoid making the often-difficult determination of whether their offering-related...
View ArticleShareholder Internal Insider-Trading Policies
Certain organizations that hold or invest in publicly traded securities may gain material nonpublic information regarding an issuer of those securities by virtue of the terms of the investment in the...
View ArticleAdoption of a Rule 10b5-1 Plan – To Disclose or Not to Disclose, Part 1
The CEO of a publicly held company determines to enter into a personal Rule 10b5-1 trading plan (“Plan”). Among other questions that arise in this circumstance is the question for this series of posts...
View ArticleAdoption of a Rule 10b5-1 Plan – To Disclose or Not to Disclose, Part 2
The preceding post in this series began to address the question whether a CEO’s adoption of a Rule 10b5-1 trading Plan should be publicly disclosed by the CEO or the company, such as through a press...
View ArticleAdoption of a Rule 10b5-1 Plan – To Disclose or Not to Disclose, Part 3
The two preceding posts in this series (1) began to address the question whether a CEO’s adoption of a Rule 10b5-1 trading Plan should be publicly disclosed by the CEO or the company, such as through a...
View ArticleSEC Brings First Whistleblower Retaliation Action Against Hedge Fund Manager.
On Monday of this week, the SEC charged hedge fund manager Paradigm Capital Management of Albany, New York with making improper principal trades and retaliating against the firm’s head trader who...
View ArticleNew Texas Crowdfunding Rules – Ten Factors to Consider
So you’d like to take advantage of the new Texas intrastate crowdfunding rules, when they’re effective in late November, to raise money for your business. That’s great, but here are ten important...
View ArticleCourt Clarifies “Personal Benefit” for Insider-Trading Liability
The recent decision of the federal Second Circuit Court of Appeals in U.S. v. Newman et al. (December 10, 2014) is noteworthy for a few reasons. Among them is the Court’s analysis and discussion –...
View ArticleQuestions Regarding New Exemptive Rules for Texas Investment Advisers to...
We have received a number of questions over the last few months regarding the new Texas investment-adviser-registration exemptive rules that became effective on March 31, 2014. These questions have...
View ArticleQuestions Regarding New Exemptive Rules for Texas Investment Advisers to...
In our previous post , we addressed a set of questions regarding the ability of an investment adviser to a private fund to remain exempt from investment-adviser registration in Texas by relying on the...
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