By: Cooper D’Anton In a discrete no-action letter last fall, the Securities and Exchange Commission (“SEC”) staff applied the disclosure Rule 15c2-11 (“15c2-11” or “Rule”) to fixed income securities – including those in the $5 trillion Rule 144A (“144A”) private placement market – for the first time in the Rule’s 50-year history.[1] Staff intends to…

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By: Scarlett Keane SPACs are the hottest IPO tool available for corporations today.[1]  SPACs, or special purpose acquisition vehicles, are shell companies designed to issue an initial public offering before acquiring a target company to bypass much of the regulation in accordance with an IPO for an existing company.[2]  Within a few months of the…

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By: Annie McEnaney Two weeks ago, the National Labor Relations Board (“NLRB” or “Board”) released a Notice of Proposed Rulemaking (“NPRM”) addressing the standard for determining an employer’s joint employer status under the National Labor Relations Act (“NLRA”).[1] The NPRM purports to replace the old, “direct and immediate control” rule that took effect on April…

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By: Brendan Glynn Robinhood is an online stock-trading application with a user base of over 10 million people.[1]  On March 2, 2020, all of those users were unable to access the platform, allegedly due to Robinhood’s failure to adequately prepare itself for a surge in the number of users, and thus the userbase was taken…

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By: Carson Hicks Last year Lucasfilm released the second season of The Mandalorian to Disney+, continuing the story of the eponymous bounty hunter, Din Djarin, and his force-sensitive ward Grogu, known more commonly as Baby Yoda.[1]  The season culminates in a finale cameo by the Chosen One himself, Luke Skywalker, saving the heroes from certain…

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By: Magdalene Eallonardo Purdue Pharma L.P. (“Purdue”), a U.S. drug maker, and its billionaire owners, the Sackler family (“Sacklers”), are facing more than 2,600 lawsuits from municipal governments and states surrounding their contribution to the opioid crisis.[1]  These claims allege Purdue deceptively marketed its prescription painkiller OxyContin and misrepresented the risks of addiction and overdose…

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By: Helena Alvarez On February 14th, 2022, the Securities and Exchange Commission (“SEC”) charged BlockFi Lending LLC (“BlockFi”), a crypto lending services provider, with: (1) failing to register its crypto lending product, BlockFi Interest Accounts (“BIAs”); (2) violating the registration provisions of the Investment Company Act of 1940; and (3) violating antifraud provisions of the…

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By: Catrina Lambert-Crittenden Economic sanctions, an increasingly popular foreign policy tool, are a mechanism to impose penalties on governments, people, or groups.[1]  Sanctions can take the form of tariffs, quotas, embargoes, and the seizure of assets.[2]  Typically, a sanctions regime applies to entities within a state’s control whether it is assets located within the country…

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