Global Financial Regulatory Blog

Tag Archives: exchange act

SEC Proposes Stricter Requirements for the Rule 10b5-1 Affirmative Defense

The Proposal would have a significant impact on current practices surrounding the use of Rule 10b5-1 plans by public companies and insiders. By Joel H. Trotter, Stephen P. Wink, Naim Culhaci, and Deric Behar On December 15, 2021, the Securities and Exchange Commission (SEC) issued a set of proposed amendments (the Proposal) regarding the adoption … Continue Reading

SEC Staff Issues Key Considerations on LIBOR Transition

As a major LIBOR transition milestone approaches, a Staff Statement provides key considerations for market participants regarding their obligations. By Laura N. Ferrell, Marlon Q. Paz, Zach Lippman, and Deric Behar On December 7, 2021, the Staff of the Securities and Exchange Commission (SEC) issued a statement (the Statement) on the transition away from the … Continue Reading

SEC Streamlines Rules for Over-the-Counter Equity Securities

The changes will have implications for the growing secondary market for non-listed securities. By Stephen P. Wink, Naim Culhaci, and Deric Behar On September 16, 2020, the US Securities and Exchange Commission (SEC) adopted amendments to Rule 15c2-11 (the amended Rule) of the Securities Exchange Act of 1934 (Exchange Act). Rule 15c2-11 sets forth requirements … Continue Reading
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