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Gary Gensler’s Most Entertaining Lines In The Kalshi Litigation
Gary Gensler's recent amicus brief in the Kalshi litigation has sparked unexpected attention across legal circles, with lawyers who typically oppose his regulatory approach finding themselves sharing excerpts from the filing. The brief challenges whether Congress intended Dodd-Frank to preempt state sports betting laws, using memorable phrases and firsthand institutional knowledge to frame a complex debate about prediction markets, federal commodities law, and state gambling authority.
United States Commercial
GU
Gesmer Updegrove LLP
Article
SEC Warns Investment Advisers: Economic Conflicts Remain A Major Examination Priority
The SEC's Division of Examinations has issued a new Risk Alert highlighting critical deficiencies in how investment advisers manage and disclose economic conflicts of interest. The alert reveals that examiners are increasingly scrutinizing cash sweep arrangements, share class recommendations, billing practices, and whether compliance programs adequately address the economic incentives embedded within advisory businesses. Firms can no longer rely solely on disclosure to satisfy fiduciary obligations—th
United States Finance
GU
Gesmer Updegrove LLP
Article
17 CFR Part 210 Explained: Regulation S-X, SEC Financial Statements, Auditor Independence, Acquired Business Financials, Pro Forma Financial Information, And Public Company Reporting
Regulation S-X governs the form, content, and requirements for financial statements filed with the SEC under various federal securities statutes. Understanding these rules is critical because financial statement issues can delay offerings, complicate acquisitions, trigger SEC comments, affect auditor review, create disclosure control issues, or become enforcement problems if the financial statements are materially misleading.
United States Commercial
GU
Gesmer Updegrove LLP
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