Tag Archives: waiver letter

Roadmap To Getting “Bad Actor” Disqualification Waived

A recent SEC no-action letter provides a road map as to how to get the staff to waive your “bad actor” disqualification from participating in private placements: claim that there was no “intent” to commit the act; say that the … Continue reading

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SEC Grants Second “Bad Actor” Waiver

The SEC has issued its second “bad actor” waiver in the case of Instinet. Instinet agreed to a settlement order arising from its payments requested by Instinet’s customer J.S. Oliver Capital Management, L.P. (“JS Oliver”) for expenses that JS Oliver had not … Continue reading

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