May 05, 2020 Articles

Circuit Courts Split on Whether Morrison Ever Applies to Domestic Transactions

The Ninth Circuit has openly disagreed with the Second Circuit’s interpretation, leaving it up to the Supreme Court to resolve.

By Gabriel K. Gillett and Philip B. Sailer

Each year, financial institutions and counsel pore over the annual priority letter and the annual priority letter issued by the Securities and Exchange Commission (SEC) for important insight into areas of focus for the upcoming year. For this article, we attended an ABA SRO Subcommittee roundtable with regulators and member firms and reviewed recent guidance and disciplinary actions to identify three main points of emphasis for 2020. This article also provides some practical tips and considerations resulting from FINRA’s recent organizational changes.

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