Monthly Archives: April 2019

SEC Framework for Analysis of Digital Assets; No-Action Relief for Certain Tokens

Posted by admin & filed under Cryptocurrencies, Securities.

On April 3, 2019, the Securities and Exchange Commission (the “SEC”) staff released a “Framework for ‘Investment Contract’ Analysis of Digital Assets” setting forth its current approach to determining when a digital asset is a security and when it is not.  The Framework does not add significantly to the SEC’s prior actions and statements in… Read more »

SEC Acts Against Private Fund Asset Transfers

Posted by admin & filed under Broker-Dealers, Funds - U.S., Investment Advisers.

On March 15, 2019, the Securities and Exchange Commission (the “SEC”) took cease and desist action against Talimco, LLC (“Talimco”), a private fund manager, and Grant Rogers, its Chief Operating Officer (“Rogers”), finding that Talimco had sold mortgage participations owned by collateralized debt obligations (“CDOs”) that it managed to a fund (the “Fund”) also managed… Read more »