Tag: compliance

Ask and Ye Shall Receive: OCIE’s 2018 Examination Priorities – Part 1 of 2

Industry professionals have noted that the SEC’s Office of Compliance Inspections and Examination (“OCIE”) was tardy in releasing their priorities list, although recent speeches from SEC officials have provided a preview of the issues in OCIE’s crosshairs. The full priority list was released on February 7. The SEC’s examination priorities identify practices, products and services … Continue Reading

Section 4(c) of the 1933 Act: The Orphan Exception from Broker-Dealer Registration – Part Two

My first post discussed the requirements for the Section 4(c) exemption from broker-dealer registration added by the JOBS Act. This second part will apply Section 4(c) of the Securities Act of 1933 to a number of situations where questions can be raised whether the activities require registration as a broker-dealer.… Continue Reading

Section 4(c) of the 1933 Act: The Orphan Exception from Broker-Dealer Registration – Part One

We have previously discussed the long-running saga regarding whether transaction-based compensation related to non-public sales of securities require registration as a broker-dealer under the Securities and Exchange Act of 1934 (“Exchange Act”). Our discussions have included (i) the tricks and treats of the SEC’s Crowdfunding release last Halloween, (ii) California’s exemption for “finders,” and (iii) a Christmas present for resellers … Continue Reading
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