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Comment Letters And The APAs

Yesterday, Broc Romanek wrote that the Commodity Futures Trading Commission had removed a comment letter from its website.  This caught my attention because I teach Administrative Law at the University of California, Irvine School of Law and this very week I had used the CFTC’s website to demonstrate to my class how the informal comment process…

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How Long Is The SEC Required To Keep Your Form 4?

Earlier this year, I tried to figure out the rules applicable to record retention at the Securities and Exchange Commission.  Here is what I’ve learned: The Federal Records Act of 1950, codified at 44 U.S.C. ch. 31, establishes the framework for records management programs for the SEC and other federal agencies. The National Archives and…

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Is Big Brother Watching You? In California, All You Have To Do Is Ask.

California’s Information Practices Act On November 7, 1972, the voters of California added the words “and privacy” to Article I, Section 1 of the California Constitution to guarantee an inalienable right of privacy.  Five years later, the California legislature enacted the Information Practices Act, Stats. 1977, c. 709, after finding that the “right to privacy…

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At The PCAOB, They Give No Words But “Mum”

In March, the Public Company Accounting Oversight Board issued its first public research note.  Entitled “Activity Summary and Audit Implications for Reverse Mergers Involving Companies from the China Region (January 1, 2007 through March 31, 2010),” the research note was prepared by the PCAOB’s Office of Research and Analysis (aka ORA). A new fine question…

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