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  1. SEC’s Latest Amendments to Regulation M. Reg Ms New Record-Keeping Obligations and FINRA Reporting Obligations. Impact on Broker-Dealers and Related Considerations. Practical Considerations and Related Market Developments. Regulation M Overview and Rules 101 and 102.

  2. Topic: Compliance issues related to Rule 105 of Regulation M, which governs short selling prior to pricing of certain offerings. Key Takeaways: Investment advisers, investment companies, and broker-dealers should review their compliance programs to promote compliance with Rule 105 of Regulation M.

  3. Rule 100 sets forth the definitions of certain terms used in Regulation M. Rules 101 and 102 regulate bids for and purchases of the offered securities and certain other covered securities. More specifically: Rule 101 regulates bids and purchases by distribution participants.

  4. The Securities and Exchange Commission adopted amendments to Rule 105 of Regulation M to further safeguard the integrity of the capital raising process and protect issuers from manipulative activity that can reduce issuers' offering proceeds and dilute security holder value.

  5. 3 Μαρ 2023 · This client alert reviews the basics of Rule 105; describes the facts in the two recent cases; and discusses how a fund manager can tailor its policies and procedures to avoid Rule 105 compliance problems.

  6. 17 Ιουλ 2013 · Rule 105 is a “strict liability” rule and applies irrespective of any intent by a short seller to violate Rule 105 (although a lack of such intent may serve as a mitigating factor to reduce the extent of the civil penalty that is imposed).

  7. 2 Απρ 2024 · Practical, Experience-Based Insights on Financial Regulatory Developments. Proskauer’s Practical Guide to the Regulation of Hedge Fund Trading Activities offers a concise, easy-to-read overview of the trading issues and questions we commonly encounter when advising hedge funds and their managers.

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