FINRA Releases 2015 Broker-Dealer Exam Priorities

by Wiggin and Dana LLP | Sep 15, 2019

On January 6, 2015, the Financial Industry Regulatory Authority (“FINRA”) released its 2015 Regulatory and Examinations Priorities Letter highlighting a number of compliance areas that FINRA examiners will focus on in the coming year. According to...

FTC Issues FAQ Advising Franchisors to Adhere to One Regulator’s Item 19 Comments in All States

by Wiggin and Dana LLP | Sep 15, 2019

On July 2, 2014, the Federal Trade Commission (“FTC”) issued Amended Franchise Rule FAQ 38. [1] FAQ 38 has not received much attention, perhaps due to the fact that the FTC’s website for posting FAQs has recently changed. In any event, FAQ 38...

Former Compliance Officer Assessed Million Dollar Penalty for Role in Company’s Money Laundering Violations

by S Z | Sep 15, 2019

Corporate officers with compliance duties, take note: you may face personal liability for your role in failing to prevent your company’s violations of federal law. This new reality comes courtesy of the U.S. Department of the Treasury’s Financial Crimes...

SEC Releases Exam Priorities for 2015

by S Z | Sep 15, 2019

On January 12, 2015, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released its Examination Priorities for 2015 (available here) outlining the issues that it will focus on this year in examining investment advisers,...

Supreme Court Changes Appellate Review Standard for Claim Construction

by Wiggin and Dana LLP | Sep 15, 2019

This week, the Supreme Court rejected the Federal Circuit’s long standing practice of applying a de novo review standard to district court claim construction decisions. Instead, in Teva Pharmaceuticals USA, Inc. V. Sandoz, Inc., No. 13–854 (Jan. 20, 2015), the...