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author christopher-i-miller

SEC Chair Gensler on Proposed Rules About Investment Adviser Custody

Reynolds Holding

FEBRUARY 16, 2023

I support this proposal because, in using important authorities Congress granted us after the financial crisis, it would help ensure that advisers don’t inappropriately use, lose, or abuse investors’ assets. Importantly, though, Congress granted us new authorities in 2010 in response to the financial crisis and Bernie Madoff’s frauds.

Compliance

Compliance Technology

Gibson Dunn Offers 2022 Year-End Securities Litigation Update

Reynolds Holding

MARCH 27, 2023

Judge Miller dissented, arguing that the majority improperly based its holding on the text of NYSE rules instead of the text of the statutes at issue; that there was no principled distinction between successive-registration cases and this one; and that the majority’s reliance on policy arguments was improper. at 952–53 (Miller, J.,

Technology

Technology Start-ups Compliance Finance

SEC Chair Gensler on Proposed Rules About Investment Adviser Custody

Gibson Dunn Offers 2022 Year-End Securities Litigation Update

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