California’s Greenhouse Gas Allowance Auction To Be Held Tomorrow

The California Air Resources Board has given notice of the first greenhouse gas allowance auction to be held tomorrow (November 14).   Last April, I wrote about the market in “Trading In California’s Greenhouse Gas Allowances – Fraud’s New Frontier?” The auction will be effected on an internet-based platform and will have a single-round, sealed-bid format.  The auction is

Trading In California’s Greenhouse Gas Allowances – Fraud’s New Frontier?

As part of California’s Cap and Trade Program, the Air Resources Board will issue will issue tradable permits (Greenhouse Gas (GHG) allowances) that authorize a permit holder to emit a specific quantity of GHGs.  Entities will obtain these GHG allowances from the ARB through an auction or reserve sale or by purchase from a marketplace. With any

Dodd-Frank Act Preempts CSL Qualification of Certain Securities

Most securities lawyers are familiar with federal preemption of state qualification requirements pursuant to Section 18 of the Securities Act of 1933 (“Securities Act”).  See, e.g., my post regarding preemption and Rule 506 offerings.  I expect that fewer lawyers are familiar with preemption pursuant to Section 28(a) of the Securities Exchange Act of 1934 (“Exchange Act”).  In