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SEC Proposes Changes to the Definitions of Dealer and Government Securities Dealer Under the Securities Exchange Act

The Rule Proposal Would Clarify Which Market Participants Are Engaged in Buying and Selling Securities for Their Own Account "as Part of a Regular Business" and Are Subject to Dealer Registration Requirements The U.S. Securities and Exchange Commission (SEC) recently proposed a new rule1 (the Proposal) which could require a diverse range of market participants to register as dealers,2 including a…

System Failure: The U S Supreme Court Fails to Dim the Climate Innovation Sector s Bright Light

By Elise N. Zoli, Peter Mostow, Todd Glass, Scott Zimmermann, Brady Berg, Robert G. O’Connor, Devon Wilson, Elizabeth Butscher, Claire Yerman, and Max Learner The U.S. is a textbook innovation economy. Exceptional dynamism intellectual and financial has driven the country s sustainability sector, and with it domestic and global economic development. The current industrial revolution, unlike the…

Compliance Reminder: SEC Disclosure Considerations Arising from Russia s Invasion of Ukraine

Many public companies are beginning preparations for filing quarterly reports on Form 10-Q for the second quarter of calendar 2022. As they do so, they should review and consider the U.S. Securities and Exchange Commission (SEC) guidance for public companies regarding disclosures pertaining to Russia s invasion of Ukraine. The guidance includes a list of disclosure considerations, as well as a…

FDA Issues Guidance on Importing Drugs from Canada

On May 25, 2022, the U.S. Food and Drug Administration (FDA) issued a guidance document intended to help pharmacists and wholesale drug distributors understand and comply with its final rule regarding the import of certain prescription drugs from Canada. The 2020 final rule, titled "Importation of Prescription Drugs," implemented Sections 804(b) through (h) of the Federal Food, Drug, and Cosmetic…

Firm Advises Silicon Valley Clean Energy on 24/7 Carbon-Free Energy Agreement with Google

On June 15, 2022, Silicon Valley Clean Energy (SVCE) and Google announced that they have completed an agreement to create a fundamentally new 24/7 renewable energy service that features hourly renewable energy matching, integrated demand management, and a commitment to ongoing community investments in local building and transportation electrification. Under the 10-year agreement, SVCE will serve…

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