Lewis Roca Blog

On April 27, 2020, the Securities and Exchange Commission issued guidance regarding investment advisory firms’ duty to disclose loans obtained under the Paycheck Protection Program (PPP) created under Section 1102 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The SEC has concluded that an advisory firm must disclose to clients that it has taken a PPP loan to counter the impact of the COVID-19 pandemic.

On April 13, 2020, the Financial Industry Regulatory Authority (FINRA) issued guidance for member firms and registered persons regarding the Paycheck Protection Program (PPP) created under Section 1102 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. FINRA specifically addressed the interaction between PPP loan forgiveness and disclosure obligations under Question 14K on Form U4.

Since March 19, 2020 Governor Ducey has issued Executive Orders to address the growing public health emergency arising from the COVID-19 virus.  These orders cover a broad range of topics aimed to address the needs faced by those who live and work in Arizona.

Unfortunately, cyber criminals see the chaos caused by the COVID-19 pandemic as an opportunity to send phishing emails which seem like they are delivered from the email domains associated with the Centers for Disease Control, the World Health Organization, the National Institutes of Health, state/local agencies, service providers and even company HR departments.

In an effort to keep you apprised of the rapid developments surrounding COVID-19, we wanted to share with you further guidance on the Financial Services Sector Essential Critical Infrastructure Workers from the U.S. Department of the Treasury.  As always, please let us know how we can help you.

Wire transfer fraud is rampant. FINRA member firms and their employees must be diligent in the detection of scams and the prevention of client losses. In addition, adherence to the member firm’s wire transfer policies and procedures is important for the avoidance of losses and potential regulatory sanctions.

Cybersecurity attorneys Doug DePeppe, Hilary Wells, Bill Nelson and Ed Barkel explore why businesses must start paying attention to their 'Cyber Hygiene' on the latest episode of the Business Leaders Podcast.