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Common Sense Reforms to Facilitate Capital Formation  


Author:  James E. Anderson.; Brian J. Baltz.


Source: Volume 58, Number 15, September 1 2025 , pp.193-200(8)




Review of Securities & Commodities Regulation

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Abstract: 

SEC Chairman Paul Atkins has an opportunity to implement many common-sense reforms of the federal securities laws. In this article, the authors discuss six actions the SEC can take: (1) withdraw SEC Staff bulletins on standards of conduct for brokerdealers and investment advisers; (2) withdraw stay of amendments to FINRA Rule 2210 to allow broker-dealers to use projected and target performance; (3) increase monetary thresholds under the M&A Broker exemption; (4) adopt an exemption from broker-dealer registration for finders; (5) update electronic delivery guidance; and (6) facilitate capital formation through private funds.

Keywords: Form PF; Investment Company Names Rule; Form N-PORT Reporting; Standards of Conduct; Private Funds

Affiliations:  1: Willkie Farr & Gallagher LLP; 2: Willkie Farr & Gallagher LLP.

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