However, in a series of no-action letters
, the SEC staff has generally indicated that it would not seek enforcement related to the distribution of articles concerning an RIA's receipt of an award where the articles are prepared by an unbiased third party, do not include an overt statement of a client's experience or a client endorsement and contain certain proscribed disclosures.
The model law would authorize an insurance regulator to grant variances, waivers, or no-action letters
with respect to the application or enforcement of requirements that discourage or prohibit the introduction of new insurance technologies, products or services.
Cipperman Compliance Services noted that while the no-action letters
are "good news for U.
Each of the 10 states has tailored its approach to granting this exemption from no-action letters
to rule changes and administrative orders.
The Proposed Rule would supersede the confusing and sometimes inconsistent SEC guidance under Release 10666, multiple no-action letters
and other SEC guidance issued over more than three decades.
The comfort given to companies from SEC no-action letters
relating to shareholder proposals has been increasingly challenged by shareholders, setting the stage for a unique proxy season.
the SEC released two no-action letters
that implied that implied that issuers could use funding portals for Rule 506(b) issuances so long as access to the portal is restricted to accredited investors.
The problem is that no-action letters
aren't themselves implementing regulations, so it's not clear whether the language of the no-action letter
will actually be effective in scoping corporate treasury centers out of the margin rule.
shareholder proposals from 2005-2012 and (2) SEC no-action letters
In addition to the creation of new funds and products, Fred regularly advises clients with respect to ongoing operations, such as periodic reporting and filing, annual reviews and approvals, exemptive applications, no-action letters
, advertising, U.
Since at least 1982, the SEC has received criticism for bypassing the rulemaking process and instead making policy through enforcement actions and no-action letters
(24)--in other words, for regulation by enforcement.
For readers wishing to explore certain topics in depth, certain key cases, SEC releases, and no-action letters
have been cited.