Last Friday, the SEC’s Division of Corporate Finance issued its fourth topic in its CF Disclosure Series, which periodically provides the SEC’s views on various topics. This time, the SEC addressed, what it believes to be, inconsistent disclosures on European sovereign debt holdings. The SEC reminds registrants, particularly bank holding companies, of their obligations to
Financial Institutions
Want to Sign Up for Regulation by the Federal Reserve?

By Gregory K. Bader on
Posted in Financial Institutions
Considering the time and expense it takes to comply with many of the Federal Reserve rules, it seems odd that any company would volunteer to be regulated. But some want to sign up. In particular, some foreign companies that own a securities broker or dealer are required to register in the U.S. to do business…
SEC Publishes Notice of Proposed Amendments to “Qualified Client” Test

By Gustav L. Schmidt on
Posted in Financial Institutions
Section 205(a)(1) of the Investment Advisers Act generally prohibits an investment adviser from collecting performance based compensation that is based on a share of capital gains on, or capital appreciation of, a client’s funds or assets under management. The Securities and Exchange Commission (“SEC”) adopted Rule 205-3 to provide exceptions to this prohibition if the…