Securities Enforcement. Corporate Investigations. Financial Regulation.

Independent analysis of the laws, regulations, investigations, and enforcement actions shaping modern financial markets.

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GESMER UPDEGROVE

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.

K. Braeden Anderson K. Braeden Anderson

Referral Programs, Finders Fees, and Interval Funds: How to Grow Without Triggering Broker-Dealer or Marketing Rule Landmines

Fintech founders love referral programs for the same reason regulators are skeptical of them: incentives work.

If you are offering an interval fund direct-to-consumer (especially on a “self-distributed” model), a well-designed incentive program can become your most efficient acquisition channel. The wrong program, or the right program implemented the wrong way, can create problems fast: unregistered broker activity, improper compensated solicitation, and RIA Marketing Rule violations, often all at once.

This article is meant to help you spot the issues early, frame the choices, and understand why “just pay people for referrals” is not a clean concept in the securities world. It is not a blueprint you can copy-paste into your business. The details matter, and the compliance architecture matters even more.

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K. Braeden Anderson K. Braeden Anderson

Commissioner Uyeda’s 2026 Disclosure Blueprint: What “Enhancing” the Public Company Framework Could Mean in Practice

On January 26, 2026, SEC Commissioner Mark T. Uyeda delivered the Alan B. Levenson Keynote Address at the 53rd Annual Securities Regulation Institute in Coronado, California, laying out a clear theme for the Commission’s next phase of disclosure policy: tighten the focus on materiality, reduce low-value compliance load, and recalibrate requirements for smaller issuers. The speech is notable not just for its tone, but for its specificity. Uyeda does not speak in abstractions. He names the parts of Regulation S-K he thinks are ripe for revision and ties the policy direction to a broader institutional effort.

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K. Braeden Anderson K. Braeden Anderson

Bloomberg Law Examines the CFTC’s Advisory Strategy as Crypto and Prediction Markets Gain Institutional Ground

Braeden Anderson, Sr. was quoted in Bloomberg Law’s article, “Crypto, Prediction Market Chiefs Gain Sway as CFTC Advisers,” by Ben Miller, where he discussed the CFTC’s evolving approach to prediction markets: “The inclusion of prediction markets in the CFTC’s innovation architecture is a clear statement that the agency intends to treat event contracts as a legitimate market-structure category within its federal remit, not as a novelty to be tolerated until the states shut it down.” Anderson added, “I would not frame Selig as ‘pro-Kalshi’ in any cheerleading sense, but I also would not assume he will shy away from defending the CFTC’s institutional lane. Everyone is looking to Selig to provide backbone here.”

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K. Braeden Anderson K. Braeden Anderson

AI Is Not a Substitute for SEC Exam Counsel

When an SEC exam request hits, some firms panic and start “Googling the exam” or relying on AI to decode what staff wants. That approach can backfire fast, leading to overproduction, credibility issues, privilege mistakes, and avoidable escalation risk. This article explains why AI is not a substitute for experienced SEC exam counsel, what exam staff is really testing, and how disciplined legal strategy can keep a routine examination from turning into a serious problem.

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