Tag Archives: bad boy

“Bad Actor” Waivers Getting Harder to Get

After giving an investment adviser that failed to get clients’ consents for 21,000 trades a “bad boy” waiver, the Securities and Exchange Commission is now considering punishing JP Morgan. The Wall Street Journal reports that the Commission is thinking about … Continue reading

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Upfront Honesty May Prevent Future Litigation

Entrepreneurs need to be prepared to answer questions from investors. This means doing a lot of prep work and acknowledging the risks of your venture. Being open and upfront about the business model, the competition, the ability to obtain paying … Continue reading

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SEC Staff Continues To Issue “Bad Boy” Waivers

The secret to obtaining a “bad boy” waiver from the Securities and Exchange Commission is to show: the bad act did not involve an intent to defraud; the misconduct did not involve the sale of securities; the actor has taken … Continue reading

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CFTC Settlement Provide for “Bad Boy” Exemptions

It pays to have smart lawyers. Money center banks who have found themselves as the subject of disciplinary orders from the Commodities Futures Trading Commission have settled cases with the inclusion of exemption language that provides them an automatic exemption … Continue reading

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Bringing “Bad Boy” Waivers Into the Light

Rep. Maxine Waters (D-CA) is talking about introducing a bill that would crack down on SEC’s “bad boy” waivers that have been handed out to the money center banks recently. The proposed legislation is apparently going to make waiver requests, … Continue reading

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Are Some Bad Actors More Equal Than Others?

Are some bad actors more worthy than others? Criminal and civil sanctions can bar banks from certain activities, including participating in the private capital markets. Securities and Exchange Commissioner Kara Stein thought so last year when the SECĀ gave a waiver … Continue reading

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Too Big For “Bad Boy” Sanctions?

The SEC Commissioners are struggling over whether a big money center bank can be “too big to be a bad actor.” Bloomberg reports that the Democratic-appointed Commissioners are arguing that Bank of America should not get a “bad boy” waiver … Continue reading

Posted in Congress, Crowd Fund Act, Crowd Fund Act of 2012, Crowd Funding At the Margins, Crowd Funding Platforms, FINRA, Funding Portals, Investments, Jobs, Legislative Intent, SEC, Wall Street | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment