Martin R. Miller

Willkie Farr & Gallagher LLP

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Recently by Martin R. Miller

Securities & Exchange Commission (SEC)

SEC Provides Guidance On “Bad Actor” Disqualifications In Rule 506 Regulation D Offerings

On December 4, 2013, the staff of the Securities and Exchange Commission (the “SEC”) Division of Corporation Finance published additional guidance (the “Guidance”) on certain key issues with respect to the new “bad actor” provisions recently added to Regulation...

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Finance

SEC Lifts Ban On General Solicitation For Certain Private Offerings, Disqualifies "Bad Actors" From Participating In Regulation D Private Offerings And Proposes Rules To Assist In Monitoring Market Practices

The Securities and Exchange Commission has adopted major amendments to the private placement safe harbor under Rule 506 of Regulation D and to Rule 144A under the Securities Act of 1933 (the “Securities Act”). The amendments will allow general advertising and general...

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Finance

Reminder: Annual Update Of Form ADV And Annual Requirement To Confirm Status Of Investors Under The New Issue Rules

Annual Update Of Form ADV The Securities and Exchange Commission (the “SEC”) requires SEC registered investment advisers and Exempt Reporting Advisers [1] to annually update the information on their Form ADVs. Form ADV is filed electronically on the Investment Adviser...

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Regulatory & Compliance

SEC Adopts Net Worth Standard For Accredited Investors Under Regulation D

Effective July 21, 2010, the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act modified the $1 million net worth test for qualifying as an “accredited investor” under Regulation D to exclude for the first time the value of a person’s primary residence.[1] The...

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Securities & Exchange Commission (SEC)

The SEC Sanctions Broker For Failure To Maintain And Enforce Insider Trading Policies

The SEC sanctioned Janney Montgomery Scott LLC ("Janney"), a registered broker-dealer and investment adviser, for violating section 15(g)1of the Securities Exchange Act of 1934 (the "Exchange Act") by failing to have and enforce policies and procedures to prevent the misuse of...

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