May 13, 2011
Turn Back the Clock! SEC Staff Issues New Electronic Roadshow No-Action Letter
I was surprised to see that the SEC’s Division of Trading and Markets issued a new no-action response related to electronic roadshows last week – this one to Roadshow Broadcast LLC.
I was surprised because a string of these letters were among the first positions that the SEC Staff took back in the late-90s related to the Internet (remember NetRoadshow I and II? Private Financial Network?) – I worked on a few of the letters when I served in Corp Fin – and then the Staff said they would issue no new letters. In 2005, the SEC adopted rules that superseded these no-action positions as part of its huge Securities Act Reform rulemaking. But I believe this new letter is different, relating to broker-dealer activity and not covering the same ground as in the prior letters. In fact, Corp Fin is not even a party to this new letter…
Your Legal Career in 6 Words or Less
I loved this “Legal Blog Watch” that cross-references Ross Fishman’s interesting challenge to lawyers and law marketers: Can you summarize your “lives, careers, experiences, firms – or just something [you’ve] been thinking about” in six words or less? Ross has many fine examples that he received on his blog.
Mine? It would be: “Still crazy after all these years,” with “Get crazy. Get loose. Go nuts” a close second…
– Broc Romanek