Will FINRA step in to prevent a ban on placement agents working with government investors? You may remember that last August, the SEC published a proposed rule that would create a prohibition on paying a third party, such as a placement agent, to solicit a government client on behalf of the investment adviser: IA-2910. The [...]
Tag Archives: Goodwin Procter
Bits and Pieces on Compliance
Here are a few stories and items that caught my eye recently, but I have not had time to build-out to a full post: Role of Federal Sentencing Guidelines in FCPA Cases from the WrageBlog Given the tremendous fines imposed upon Siemens AG and Kellogg Brown & Root LLC (“KBR”) in the past 10 months, [...]
FBAR Filing Deadline Extended (For Some)
The deadline for Foreign Bank Account Reporting was June 30. The Report of Foreign Bank and Financial Account is IRS TD F 90-22.1 (.pdf). Any United States person who has a financial interest in or signature authority, or other authority over any financial account in a foreign country, if the aggregate value of these accounts [...]
Enterprise 2.0 at Goodwin Procter
Can law firms jump on the Enterprise 2.0 bandwagon? Lawyers are generally seen as conservative users of technology, preferring to use a quill and inkwell over a web-based publishing platform. David Hobbie shares some of the successes he has encountered in the adoption of Enterprise 2.0 at Goodwin Procter (.pdf – page 13) in the [...]
Electronic Filing of Form D and Amendments Becomes Mandatory on March 16
Beginning March 16, 2009, Form D filings are required to be made electronically on EDGAR. See SEC Release No. 33-8891 (February 6, 2008). Form D is commonly used for offerings made under the Rule 506 safe harbor to accredited investors. While the filing of a Form D is not a condition to the exemption, it [...]
Proposal to Tax Carried Interests as Ordinary Income
The Obama Administration has labeled their 2010 budget as A New Era of Responsibility. Part of that responsibility appears to be taxing carried interest as ordinary income. On page 122 of the budget there is a single line item: “Tax carried interest as ordinary income,” with projections of $2,742 million in 2011, $4,347 million in [...]
Amendment to Mass. Data Privacy Law
Goodwin Procter has published a client alert describing the amendments to the Massachusetts Data Privacy Law (my posts on this topic). They detail three changes. First is pushing bck the complaince deadline to January 1, 2010. Second, theyhave lifted some of the contract amendments and certifications from vendors. Third, they clarified the wireless encryption requirement. [...]
Recent Changes to the ADA and FMLA
Goodwin Procter presented a webinar on recent changes to the Americans with Disability Act and the Family and Medical Leave Act. Rob Hale moderating the presentation. Heidi Goldstein Shepherd led off with a background on the ADA. The key concept for employers is that it is up to the employee to request a “reasonable accommodation” [...]
The New Massachusetts Data Security Regulations
Goodwin Procter sponsored a webinar on the new Massachusetts date security rules Lynne Barr Deb Birnbach Agnes Bundy Scanlan David J. Goldstone Jacqueline Klosek Deb pointed out that you may now need to collect the state of residence of the client to figure out if they are in Massachusetts. That may have the perverse effect [...]
Strategies for Responding to Liquidity Needs of Investors in Real Estate Funds
Goodwin Procter put together a great piece on Strategies for Responding to Liquidity Needs of Investors in Real Estate Funds. As a result of the current economic downturn and global economic credit crisis, some investors find themselves over-allocated to investments in private real estate funds because their private real estate investments have not been written [...]
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