I'm reminded of the late great comic George Carlin and his love for words and needling the establishment. During his standup on the first episode of Saturday Night Live, he famously quipped, "The term jumbo shrimp has always amazed me. What is a jumbo shrimp? I...
What a year this was! As my law firm gets ready to host hundreds of people for its annual New Year's Eve event (we have a perfect view of the ball drop in our Times Square office), I'm thinking about how much has happened in...
A new omnibus spending bill announced by US lawmakers contains an interesting provision: "None of the funds made available by any division of this act shall be used by the Securities and Exchange Commission to finalize, issue or implement any rule, regulation or order regarding the disclosure...
The Jumpstart Our Business Startups (JOBS) Act of 2012 preempted state blue sky registration and qualification for what ultimately became Tier II Regulation A offerings under new SEC rules. So they cannot give comments on, hold up or prevent a company from offering Reg A+...
Updated 2:39pm on 12-9-2015 They got tucked into a transportation bill (Fixing America's Surface Transportation Act or the FAST Act), but with a deft set of amendments the Reforming Access for Investments in Startup Enterprises Act of 2015 (or the RAISE Act) and other small business initiatives...
As I have for many years, last week I attended the SEC's annual business conference on smaller companies in our nation's capital. Always love my trips to DC- I especially liked when my breakfast waiter called me Senator (flattery gets you a good tip)! Now...
Last week the SEC announced it is allowing the national securities exchanges to wait until October 2016 to implement its highly vaunted tick size pilot program. Originally the plan was to commence in May, but the SEC feels the exchanges (and FINRA) need more time...
A series of questions comes with the news last week that for the third time in the last year a well-known microcap securities lawyer has been arrested and charged with securities fraud. What is the responsibility of an attorney representing a public company or investors...
It was in many ways the centerpiece of the Jumpstart Our Business Startups (JOBS) Act of 2012. At the signing ceremony all the President could talk about was the idea of "bringing Wall Street to Main Street." And while the JOBS Act has many other...
As announced earlier this week, the SEC today approved final rules for Jumpstart Our Business Startups (JOBS) Act Title III "crowdfunding." We don't have all the details yet but it looks mostly like they proposed it, with a $1 million limit on crowdfunding, limits on what...