Recent Posts

The Disqualification Provisions and the SEC’s Use of Wavers
Posted on 16 Mar 2015 by Thomas O. Gorman

One key debate regarding current SEC enforcement policy centers on the application of the so-called “bad actor” provisions. Previously the Commissioners split over the nature, use and application of those provisions. Central to the debate... Read More

SEC Implements the “Bad Actor” Disqualification Provisions of Dodd-Frank
Posted on 30 Jul 2013 by Alexander Davie

Previously, I summarized the Securities and Exchange Commission’s implementing regulations of Title II of the JOBS Act , lifting the ban on general solicitation for offerings exempt under Rule 506 of Regulation D, which were finalized on July 10... Read More