Securities Enforcement. Corporate Investigations. Financial Regulation.
Independent analysis of the laws, regulations, investigations, and enforcement actions shaping modern financial markets.
BRAEDEN ANDERSON
Braeden is one of the top securities lawyers in the country and was recognized by Best Lawyers: Ones to Watch® in America in the Financial Services Regulation Law and Securities Regulation categories. This honor is awarded to only the top 2% of attorneys in the United States and is based on a comprehensive peer-review survey.
Braeden helped lead Gesmer Updegrove to recognition in The Legal 500 United States for Corporate Investigations & White Collar Crime, Tier 3, and Finance: Fintech, Tier 4.
Braeden is active in the U.S. securities enforcement community through Securities Docket, where he has served on the 2025 and 2026 Advisory Boards and contributed video commentary through the Weekly Update.
Braeden was named the #1 United States author in FinTech in Mondaq’s Spring 2025 Thought Leadership Awards, reflecting the national reach and influence of his writing on fintech, securities regulation, and digital asset policy.
Evergreen Guide: Broker-Dealer Due Diligence Obligations in Regulation D Offerings
Private placements under Regulation D of the Securities Act of 1933 remain a critical avenue for capital formation, particularly among early-stage and smaller companies. Despite their exemption from registration, these offerings are not exempt from the antifraud provisions of the federal securities laws. Broker-dealers that recommend Regulation D securities must undertake a reasonable investigation into the offering, the issuer, and the surrounding circumstances. This obligation stems from SEC and FINRA rules and is central to satisfying suitability, antifraud, and supervisory compliance requirements. This guide summarizes the regulatory foundation and outlines best practices for broker-dealers conducting due diligence in Regulation D offerings, with particular reference to FINRA Regulatory Notice 10-22.
FINRA Proposes Modernization of Rules Governing Member Firm Workplaces
On April 14, 2025, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 25-07, requesting comment on whether and how its rules, guidance, and processes governing the organization and supervision of member firm workplaces should be modernized to reflect significant shifts in industry operations. The comment deadline has been extended to July 14, 2025.
FINRA Finalizes SLATE Rule 6540: The Definitive Guide to Securities Lending Transparency Requirements (Effective 2026)
On April 2, 2026, FINRA Rule 6540 under the new SLATE (Securities Lending and Transparency Engine) Rule 6500 Series will take effect, ushering in a new era of regulatory transparency in the securities lending market. Mandated by SEC Rule 10c-1a under the Securities Exchange Act of 1934, FINRA’s new framework sets out detailed reporting and public dissemination requirements for securities loans and their modifications. These changes represent a significant expansion in regulatory oversight and transparency and will affect broker-dealers, agent lenders, institutional investors, and other market participants engaged in securities lending. This guide outlines the obligations, timeline, mechanics, legal challenges, and implications of Rule 6540 in a comprehensive manner, providing all the information market participants need to comply and strategize under the new regime.
Treasury Secretary Bessent Outlines Strategic Vision for Financial Regulatory Reform at Federal Reserve Capital Conference
In prepared remarks delivered at the Federal Reserve Capital Conference, U.S. Treasury Secretary Scott Bessent outlined a sweeping and assertive vision for reorienting the nation's financial regulatory architecture. Framing the speech as a call to action, Bessent emphasized the urgent need to move beyond reactive, fragmented regulation and toward a coordinated, long-term blueprint centered on economic growth, innovation, and national security.
Treasury Postpones Effective Date of Investment Adviser AML Rule; Signals Broader Reassessment of Regulatory Framework
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced today its intent to postpone the effective date of its final rule imposing anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) requirements on investment advisers (the “IA AML Rule”).