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FINRA Exam Priorities For Regulation Best Interest

On January 9, 2020, the Financial Industry Regulator Authority (“FINRA”) published its 2020 Risk Monitoring and Examination Priorities Letter (the “Letter”).  The Letter made clear that the new Reg BI (also known as the “Best Interest” regulation), adopted by the Securities and Exchange Commission on June 5, 2019, would be its top priority in 2020. ... Read more »

SEC Proposes Revisions to “Accredited Investor” and “Qualified Institutional Buyer”

Among the key thresholds under Regulation D and Rule144A for eligibility for investing in private securities offerings are the definitions of “accredited investor” and “qualified institutional buyer”.  In mid-December of 2019, the Securities and Exchange Commission approved, by a vote of 3-2, a proposal to revise these definitions.  The current categories and financial thresholds remain... Read more »

UK-EU Trade Agreement Tall Order on UK Government Brexit Timetable

Now that Brexit is a reality and the U.K. has left the European Union (the “EU”), the issue of what comes next unfortunately is not over.  The U.K. government of Boris Johnson is seeking to finish a trade agreement with the E.U. by the end of December 2020.  Many experts believe that completing and ratifying... Read more »

New Committee on Foreign Investment in the United States (“CFIUS”) Rules to Go Into Effect

On February 13, 2020, new CFIUS rules are scheduled to go into effect. The new rules have been adopted by the Treasury Department under the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) which increases the CFIUS authority to review and disallow investment in U.S. sensitive companies.  The rules also resulted in the exemption... Read more »

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