Nicolas Morgan

Onchain, With Strings: The proposal permits blockchain recordkeeping but does not require it. Personal information stays offchain, and each issue can have only one recordkeeping agent. Can an agent “control” a record on a public network it does not run?

Why can't investment advisers donate to political candidates even after the SEC proposed to repeal its pay-to-play rule? In SEC Roundup Episode 105, Nick Morgan and Mark Hiraide talk with Hardy Callcott of Sidley Austin about the SEC's proposal to rescind Rule 206(4)-5, the automatic two-year compensation ban it triggers, and why MSRB Rule G-37, FINRA Rule 2030 and state and local laws keep most political giving bans in place. Comments on the proposal close Nov. 9.

Why is the SEC still suing an immigration attorney over accredited investor verification while moving to loosen the accredited investor definition? In SEC Roundup Episode 104, Nick Morgan and Tom Zaccaro talk with ICAN client Mona Shah about the SEC's Section 5 case over EB-5 offerings, Rule 506(c) verification, and what the SEC's Sept. 30 credential and FINRA exam proposal means for advisors, broker-dealers and other gatekeepers.