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.
SEC Extends Compliance Date for Daily Reserve Computation Requirements Under Rule 15c3-3
On June 25, 2025, the Securities and Exchange Commission announced an extension of the compliance deadline for broker-dealers subject to its December 2024 amendments to Rule 15c3-3—the Customer Protection Rule. The amendments require certain broker-dealers to compute reserve requirements daily rather than weekly. The new compliance deadline has been extended from December 31, 2025, to June 30, 2026, providing firms with six additional months to complete the transition.
SEC Releases Data on Broker-Dealers, M&A Activity, and Business Development Companies
On June 26, 2025, the SEC’s Division of Economic and Risk Analysis (DERA) published three detailed reports providing updated data and analysis on broker-dealers, mergers and acquisitions (M&A), and business development companies (BDCs). These reports are part of the agency’s ongoing effort to enhance transparency and provide market participants with relevant data to support regulatory and commercial decision-making.
U.S. Treasury’s Overreach in Crypto Broker Reporting Sparks Industry Outrage
Recent developments in Treasury’s crypto broker reporting regulations have ignited heated debate across the digital asset community. At the heart of the controversy lies a significant overreach: Treasury’s expanded definition of “broker” now includes entities like informational websites, platforms with "connect wallet" features, and other services that merely provide users with data they can use to transact on blockchain networks. This interpretation, codified in TD 10021, has drawn sharp criticism for its legal overextension and potential to stifle innovation in the burgeoning crypto sector.