The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Wed, 22 Jul 2026 19:20:14 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png SEC Division of Trading and Markets Issues Guidance on JOBS Act – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 SEC Division of Trading and Markets Issues Guidance on JOBS Act https://corpgov.law.harvard.edu/2012/09/17/sec-division-of-trading-and-markets-issues-guidance-on-jobs-act/?utm_source=rss&utm_medium=rss&utm_campaign=sec-division-of-trading-and-markets-issues-guidance-on-jobs-act https://corpgov.law.harvard.edu/2012/09/17/sec-division-of-trading-and-markets-issues-guidance-on-jobs-act/#comments Mon, 17 Sep 2012 12:47:46 +0000 http://blogs.law.harvard.edu/corpgov/?p=32980?d=20150113140048EST Posted by Giovanni P. Prezioso, Cleary Gottlieb Steen & Hamilton LLP, on Monday, September 17, 2012
Editor's Note:

Giovanni Prezioso is a partner focusing on securities and corporate law matters at Cleary Gottlieb Steen & Hamilton LLP, and former General Counsel of the Securities and Exchange Commission. This post is based on a Cleary Gottlieb memorandum by Leslie Silverman.

On August 22, 2012, the SEC Division of Trading and Markets (the “Staff”) published answers to 14 frequently asked questions (“FAQs”) relating to certain provisions of Title I of the Jumpstart Our Business Startups Act, signed into law on April 5, 2012 (the “JOBS Act”), affecting research analyst and investment banking personnel conduct in connection with emerging growth companies (“EGCs”).

The most noteworthy guidance, in our view, relates to the following:

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