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Nov 2016
SEC Issues Guidance on Fund Business Continuity Planning

SEC Issues Guidance on Fund Business Continuity Planning On June 28, 2016, the SEC’s Division of Investment Management issued a Guidance Update titled, Business Continuity Planning for Registered Investment Companies (the “Guidance,” available here). The Guidance states that a fund complex should consider its compliance obligations under the federal securities laws when assessing its ability to continue......

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Prop 47: $950 Difference Between Felony & Misdemeanor
November 11, 2016

Prop 47: $950 Difference Between Felony & Misdemeanor

Prop 47: $950 Difference Between Felony & Misdemeanor California’s Proposition 47 raises interesting questions in terms of how much certain crimes will cost law-abiding citizens, vs. how much those crimes financially burden our prison system....


SEC Adopts Final Rules on CEO Pay Ratio Disclosure
November 07, 2016

SEC Adopts Final Rules on CEO Pay Ratio Disclosure

SEC Adopts Final Rules on CEO Pay Ratio Disclosure Companies are required to disclose the ratio of median employee annual total compensation to CEO annual total compensation starting in the 2018 proxy season; foreign private...


VimpelCom Settles FCPA Case – Part III
November 02, 2016

VimpelCom Settles FCPA Case – Part III

VimpelCom Settles FCPA Case – Part III Today, I continue my exploration of the lessons to be learned from the VimpelCom Ltd. (VimpelCom) Foreign Corrupt Practices Act (FCPA) enforcement action. While it is clear that...


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