Posts from June 2014.
On June 16, 2014, the SEC entered an order (the "Order") instituting cease and desist proceedings against an investment adviser, Paradigm Capital Management, Inc. ("Paradigm"), and Paradigm's founder, Director, President, Chief Investment Officer, and Portfolio Manager, Candace King Weir ("Weir"). The Order made findings and imposed a cease and desist order against Paradigm and Weir. In the Order, the SEC found that Paradigm and Weir had engaged in improper trading activity and that Paradigm had retaliated against Paradigm's head trader (the "Whistleblower") after ...
Posted in: SEC

Earlier this week, the U.S. Supreme Court released its decision in Halliburton Co. v. Erica B. John Fund, Inc., (U.S., No. 13-317)( Halliburton II), and for a second time vacated a decision by the Fifth Circuit on whether the case should proceed as a class action. The plaintiff in the Halliburton case alleges that defendants made misrepresentations that were designed to inflate Halliburton's stock price in violation of § 10(b) of the Securities Exchange Act of 1934 and Securities and Exchange Commission Rule 10b-5. In Halliburton II, in seeking reverse the lower court's ...

Financial services firms oftentimes can find themselves in the unenviable position of being in the middle of a dispute over money or property held by their clients. If two or more parties assert competing claims to the ownership of assets held at a financial institution, the institution with custody of the account-the "stakeholder"-can initiate a complaint in interpleader to allow a court to determine the rightful owner of the assets and obtain a discharge from further liability. Here is how an interpleader action operates and how it can protect the stakeholder: When a ...

On June 23, 2014, BrokerCheck Information makes publicly available information regarding investment-related civil action(s) brought by a state or foreign financial regulatory authority dismissed pursuant to a settlement agreement about former associated persons of a FINRA member firm that were registered on or after August 16, 1999. Established in 1988, the public disclosure program known as BrokerCheck assists investors in making informed choices about the individuals and firms with which they conduct business. Past settlements will now be disclosed publicly for ...

Posted in: FINRA
On May 20, 2014, the Securities and Exchange Commission initiated proceedings to determine whether to approve a proposal by the Financial Industry Regulatory Authority, Inc, (FINRA) to amend the NASD and FINRA rules governing estimated valuations for unlisted direct participation program (DPP) and real estate investment trust (REIT) securities. On January 31, 2014, FINRA filed a proposed rule change to amend NASD Rule 2340 (Customer Account Statements) and FINRA Rule 2310 (Direct Participation Programs), both of which address per share estimated valuations for unlisted DPP ...
Posted in: FINRA, SEC
On June 4, 2014, the United States Court of Appeals for the Second Circuit vacated and remanded a November 28, 2011 order from the United States District Court for the Southern District of New York refusing to approve a consent decree entered into by the Securities and Exchange Commission ("SEC") and Citigroup Global Markets, Inc. ("Citigroup") and setting the case for trial. In doing so, the Second Circuit held that the proper standard for reviewing a consent decree with an enforcement agency requires that a district court: "determine whether the proposed consent decree is fair and ...
Posted in: SEC

I wrote earlier that the SEC was wrong to extend its "admission of wrongdoing" policy (once reserved for extreme cases) to negligent software-glitch misreporting of trade-data in the Scottrade case. Burr blog here, (April 17, 2014); Law360 Securities article here, (June 2, 2014). On June 4, FINRA announced that its response to similar blue-sheet violations by three firms was a standard AWC ("neither admit nor deny") with a fine of less than half the amount assessed Scottrade by the SEC. As in Scottrade, the firms' violations stemmed from software problems and FINRA also found ...

Posted in: FINRA, SEC

I recently wrote about Judge Rakoff's refusal to enter the SEC's proposed consent decree in SEC v. Citigroup Global Markets, Inc., 827 F. Supp. 2d 328 (SDNY 2011) - and the shift in SEC enforcement policy that it prompted. Burr blog here, (April 17, 2014); Law360 Securities article here, (June 2, 2014). On June 4, the Second Circuit reversed the Citi ruling, holding the District Court "abused its discretion by applying an incorrect legal standard." United States Securities & Exchange Comm'n v. Citigroup Global Markets, Inc., Nos. 11-5227-cv(L); 11-5375-cv(con); ...

Posted in: SEC
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