Parrino, Richard J.; Dye, Alan; Bahn, Alex - In: Journal of Investment Compliance 19 (2018) 1, pp. 20-27
Purpose: This paper examines a legal bulletin issued by the staff of the Securities and Exchange Commission (SEC) in November 2017 that provides significant new guidance to SEC-reporting companies on the application of the “ordinary business” and “economic relevance” exceptions in Rule...