Last week, the North American Securities Administrators Association issued a comment letter urging the Securities and Exchange Commission not to move forward on its proposal to issue a conditional order exempting finders from the requirement to...
Yesterday's big news at the Securities and Exchange Commission was a proposed exemptive order for finders. The question of whether issuers can compensate anyone other than a registered broker for finding investors has bedeviled attorneys and...
Yesterday's post concerned possible arguments that federal law preempts Nevada's fiduciary standard for broker-dealers. At present, any preemption would have to be based on the National Securities Markets Improvement Act and/or the Dodd-Frank...
The 2014 Budget Act requires the Department of Business Oversight to provide a report on its broker-dealer/investment adviser program to the the Legislature and the Department of Finance by January 10 of each year. While not exactly...
Yesterday's post chided Glass, Lewis & Co., LLC for its inconsistent positions on majority rule. Today's post tackles a foolish inconsistency in the California Codes. Section 25217(c) of the California Corporations Code provides:
Is your California securities broker-dealer a licensed personal property broker? Does it need to have such a license to make loans to its customers? Anyone reading California Corporations Code Section 25217(c) would conclude that it must:
The Commissioner of Business Oversight's final regulations implementing a new exemption for finders from the broker-dealer provisions of the Corporate Securities Law took effect on June 21, 2017. See 10 CCR §§ 260.211.4, 260.211.5, 260.211.6 and...
Nearly one year ago, the California Department of Business Oversight proposed regulations to implement the provisions of AB 667 (Wagner). The bill, which was enacted in 2015 and took effect last year, created a new exemption from the broker-dealer...
Last July, the California Department of Business Oversight proposed regulations to implement the provisions of AB 667 (Wagner). The bill, which was enacted in 2015 and took effect last year, created a new exemption from the broker-dealer...