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Senior Counsel Jim Bowers outlined the Federal Trade Commission's Identity Theft Red Flags Rule, newly revised to limit what type of companies fall under its purview, in a January 24th article for Corporate Compliance Insights. The revised rule goes into effect February 11. Jim writes that the definition of "creditor" has been tightened, and that companies must also determine whether they have any "covered accounts" in assessing whether they are subject to the regulations, although "[e]ven in the absence of a legal obligation, implementing a program containing elements of the rule would help companies mitigate the risk of identity theft and reduce their overall exposure."
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Jeffrey A. Clopeck, Henry Nelson Massey and Eliza Sporn Fromberg wrote the article, "SEC's Dating Advice For Internet Platforms And Its Impact," for Law360. The article analyzes how some internet platforms are offering private placements in reliance on Rule 506(b) of Regulation D with approval from the Securities and Exchange Commission. This form of "speed dating" with prospective investors by Internet platforms offering private placements is allowed so long as the platform asks probing questions.
Day Pitney Alert
Stamford, Conn., August 24, 2015 - Day Pitney is pleased to announce that 68 attorneys have been selected for inclusion in the 2016 Best Lawyers in America. Best Lawyers ranks lawyers through peer-review surveys, and has been published annually since 1983.
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