Second Circuit Affirms SEC Settlement Policy

The Second Circuit recently affirmed the Securities and Exchange Commission’s ability to negotiate settlements without requiring an admission of wrongdoing, thus vacating and remanding a decision to the contrary by Judge Jed S. Rakoff of the Southern District of...

Red Flag Rules Compliance Deadline Approaches

In April 2013, the SEC and the U.S. Commodity Futures Trading Commission jointly issued final rules (the “Red Flag Rules”) requiring certain investment advisers and other regulated entities to develop and implement written identity theft prevention...