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‘Enforcement 40’ for 2020
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March 25 Webcast: Leveraging Data Analytics to Minimize Risk in the Financial Services Industry
Please join Joshua Dennis, Ellen Lafferty, Dan Ward and A.J. Bosco for this webcast.
SEC Enforcement for Internal Control Failures
On January 29, 2019, the SEC announced four settlements with publicly-traded companies for failure to maintain adequate internal control over financial reporting (ICFR). None of the companies was charged with making false or inaccurate statements, either about its ICFR or otherwise; indeed, each had repeatedly disclosed material weaknesses in ICFR over many years. These cases […]
The Time Has Come to Address Rule 10b5-1 Trading Plans and Their Shortcomings | New York Law Journal
This proposed legislation creates an opportunity to address the criticism the Rule has faced and can further curtail incidents of insider trading by preventing the successful manipulation of trading plans. The bill directs the SEC to consider whether Rule 10b5-1 should be amended to: (1) limit an insider’s ability to adopt a trading plan during […]
Fraud in Cryptocurrency, and How the SEC Is Applying Federal Securities Laws to Stop It | New York Law Journal
The cryptocurrency space continues to grow rapidly, and multiple federal and state agencies are trying to regulate these evolving markets. It remains unclear which agencies are best suited for the task, and whether existing laws are well designed to protect the public from this market’s inherent risks. The disclosure-based federal securities laws would seem to […]