Comments of the Corporation, Finance and Securities
Law Section: Part B
- Recommendations
We divide our recommendations into ten sections:
- The definition of "appearing and practicing before the
Commission in the representation of an issuer"
- The definition of "evidence of a material violation"
- The requirement in Proposed Part 205.3(a) that "[a]n attorney
appearing and practicing before the Commission in the representation
of an issuer…shall act in the best interest of the issuer
and its shareholders"
- The reporting requirement of Part 205.3(b)(1)
- The attorney documentation and recordkeeping provisions
- The requirement that the attorney assess whether the issuer
has provided an appropriate response
- The noisy withdrawal provisions
- The supervisory attorney provisions
- The qualified legal compliance committee provisions
- The sanctions provision
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