Monthly Archives: January 2013
How To Bring A Delinquent Exchange Act Reporting Company Current
SEC Delinquent Filers Program
In 2004 the Securities and Exchange Commission (“SEC”) instituted the Delinquent Filers Program and created the Delinquent Filers Branch as part of its Division of Enforcement. The Delinquent Filers Branch was instituted to encourage publicly traded companies that are delinquent in the filing of their required periodic reports (Forms 10-K and 10-Q) under the Securities Exchange Act of 1934 (“Exchange Act”) to provide investors with accurate financial information upon which to make informed investment decisions. The securities registrations of issuers that fail to make their required periodic filings are subject to suspension or revocation by the SEC and other enforcement proceedings.
Since it was instituted, the SEC Delinquent Filers Branch has suspended the trading and/or revoked the registration of hundreds of companies, often in sweeps of large groups of filers in a single day. Generally, a delinquent filer would receive a letter from the SEC giving the Company 10 days in which to make the filings current, and if such filings were not made current during that time, the SEC would institute administrative proceedings to revoke the registration of the Company’s securities.
Becoming Current
During the early years of the program, the SEC would not allow a multi-year or comprehensive filing, but would require the Company to file all missing reports (3 10-Q’s and 1 10-K for each year delinquent). However, during the recession, and in particular 2008-2012, many companies subject to the Exchange Act reporting requirements became delinquent in the filing of such reports for valid and unavoidable business reasons. In an effort to assist these entities in becoming current with their reporting requirements, the SEC, under certain circumstances, now allows the filing of a multi-year comprehensive 10-K in lieu of the filing of each and every missing report.
Accordingly, a Company that is delinquent in its reporting requirements has three options to become current in its reporting requirements. Upon filing the delinquent reports, the Company will satisfy the current information requirement for use of Rule 144 and will satisfy the “filed all reports” requirement for use of Form S-8.
Option A: File All Past Due Exchange Act Reports
This option is fairly self-explanatory; however, a few practice notes are helpful. In preparing and writing the past due reports, the drafter should complete all the information to the current date of filing the report. That is, the description of the business and business plans, the names and bios of the officers and directors, the sale of unregistered securities—basically everything—should be written as of the date of filing. In addition, there should be an added section in the MD&A which discusses the financial statements attached to that particular report and addressing that particular period. Where appropriate, historical information should be disclosed. So, for example, if the officers and directors have changed, there should be an explanatory disclosure as to the changes and historical information presented, followed by the current officer and director information as of the date of filing.
Accordingly, when completing all past due filings, the bulk of each document will be exactly the same, with the differences consisting of the financial statements, the MD&A section discussing the financial statements for that particular period, and the front page disclosing the date for which the report applies. Each report will be signed and certified by the current chief executive and accounting officers.
Filing all delinquent reports will not satisfy the requirement that a Company has “timely filed” all periodic reports, but it will satisfy the requirement that the Company has filed all reports required to be filed over the subject period of time.
Option B: Request Permission for and File a Multi-year Comprehensive Form 10-K
A Company desiring to file a multi-year comprehensive Form 10-K must obtain permission from the SEC, which requires a great deal of initial groundwork to demonstrate the ability to file the required report in a timely fashion. In particular, a Company desiring to file a multi-year comprehensive Form 10-K must submit correspondence to the SEC’s Office of Chief Accountant at the Division of Corporation Finance that:
- Lists all missing periodic reports;
- Describes in relative detail the reason for the delinquency and explains why and how the Company intends to resume reporting;
- Details how the Company intends to complete the multi-year comprehensive Form 10-K, including the exact financial statements to be included, the date the filing will be made, the auditor that has been retained (it is helpful for the auditor to include a statement that he or she has, in fact, been retained and are engaging in the required services), and any other supportive facts demonstrating the Company’s ability to comply with the request;
- Details any information that will not be included in the report that otherwise would be required and the reason for the exclusion (for example, lost or destroyed records) and requesting relief from the inclusion of such information under Rule 409 of the Exchange Act (Rule 409 allows a company to exclude information that is unknown and not reasonably available without unreasonable effort or expense with proper explanations of why the information cannot be obtained and the materiality of the missing information);
- Requests that the SEC staff not object to the filing of the multi-year comprehensive Form 10-K in lieu of all individual delinquent reports; and
- Promises to file all required future reports in a timely manner
Of course, competent counsel should be retained to either make the submission on the Company’s behalf or assist in the process. Generally, the SEC responds within 10 days. The SEC response reminds the Company that the SEC does not relieve reporting requirements, but that it may accept the one-time multi-year comprehensive Form 10-K as long as such document contains all of the following:
- Audited financial statements for each delinquent fiscal year;
- A section in the MD&A discussing the financial statements for each set of financial statements filed in the report, including quarterly statements, and a prior year or quarter comparison of results of operations for each year end period provided;
- Unaudited summarized financial statements for each of the three quarters (and prior year comparisons) for at least the last two fiscal years;
- All material information that would have been disclosed in the delinquent periodic reports had they been filed.
The multi-year comprehensive Form 10-K should be current to the date of filing, including the discussion of the business and business plans. Additional disclosures and risk factors may appropriate related to missing information, reasons for the delinquency in reporting, the impact of the delinquency in reports (such as Form S-3 eligibility), weaknesses in internal controls, and how the Company intends to rectify its issues and remain current in its reporting requirements in the future.
As with Option A, the multi-year comprehensive Form 10-K will not satisfy the requirement that a Company has “timely filed” all periodic reports, but it will satisfy the requirement that the Company has filed all reports required to be filed over the subject period of time. Upon filing the multi-year comprehensive Form 10-K, the Company will satisfy the current information requirement for use of Rule 144 and will satisfy the “filed all reports” requirement for use of Form S-8.
Option C: Terminate Exchange Act Registration by Filing a Form 15 Followed by a Form 10 Registration Statement
If a Company qualifies to do so, they may file a Form 15, terminating its Exchange Act registration and thereby relieving it of the Exchange Act reporting requirements. To qualify to file a Form 15, a Company currently must either have fewer than 300 shareholders, or fewer than 500 shareholders if it has assets of less than $10 million.
As I have blogged about in depth in the past, Title V of The JOBS Act amends Section 12(g) and Section 15(d) of the Exchange Act as to threshold shareholder requirements and registration and deregistration requirements such that the shareholder threshold before requiring registration and subsequent reporting with the SEC has been increased from 500 to either (a) 2,000 or more, or (b) 500 or more unaccredited shareholders. I expect that the SEC will implement rules to amend Exchange Act Rule 12g-4 to conform with Section 12(g).
A Form 15 does not technically relieve a Company’s obligation to file past due reports (only future reports); however, in practice the SEC does not generally require such filings.
An Issuer that files a Form 15 may thereafter file a new Form 10 registration statement subjecting it to the Exchange Act reporting requirements going forward. As with all Form 10 registration statements, the Form 10 will include two years of audited financial statements.
Option C is especially attractive to a Company that is in excess of two years delinquent in its reporting requirements and cannot reasonably obtain the records necessary to complete its audits for those years beyond the two-year period.
The Author
Laura Anthony, Esq.
Founding Partner
Legal & Compliance, LLC
Corporate, Securities and Going Public Attorneys
LAnthony@LegalAndCompliance.com
Securities attorney Laura Anthony and her experienced legal team provides ongoing corporate counsel to small and mid-size private companies, OTC and exchange traded issuers as well as private companies going public on the NASDAQ, NYSE MKT or over-the-counter market, such as the OTCQB and OTCQX. For nearly two decades Legal & Compliance, LLC has served clients providing fast, personalized, cutting-edge legal service. The firm’s reputation and relationships provide invaluable resources to clients including introductions to investment bankers, broker dealers, institutional investors and other strategic alliances. The firm’s focus includes, but is not limited to, compliance with the Securities Act of 1933 offer sale and registration requirements, including private placement transactions under Regulation D and Regulation S and PIPE Transactions as well as registration statements on Forms S-1, S-8 and S-4; compliance with the reporting requirements of the Securities Exchange Act of 1934, including registration on Form 10, reporting on Forms 10-Q, 10-K and 8-K, and 14C Information and 14A Proxy Statements; Regulation A/A+ offerings; all forms of going public transactions; mergers and acquisitions including both reverse mergers and forward mergers, ; applications to and compliance with the corporate governance requirements of securities exchanges including NASDAQ and NYSE MKT; crowdfunding; corporate; and general contract and business transactions. Moreover, Ms. Anthony and her firm represents both target and acquiring companies in reverse mergers and forward mergers, including the preparation of transaction documents such as merger agreements, share exchange agreements, stock purchase agreements, asset purchase agreements and reorganization agreements. Ms. Anthony’s legal team prepares the necessary documentation and assists in completing the requirements of federal and state securities laws and SROs such as FINRA and DTC for 15c2-11 applications, corporate name changes, reverse and forward splits and changes of domicile. Ms. Anthony is also the author of SecuritiesLawBlog.com, the OTC Market’s top source for industry news, and the producer and host of LawCast.com, the securities law network. In addition to many other major metropolitan areas, the firm currently represents clients in New York, Las Vegas, Los Angeles, Miami, Boca Raton, West Palm Beach, Atlanta, Phoenix, Scottsdale, Charlotte, Cincinnati, Cleveland, Washington, D.C., Denver, Tampa, Detroit and Dallas.
Contact Legal & Compliance LLC. Technical inquiries are always encouraged.
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Legal & Compliance, LLC makes this general information available for educational purposes only. The information is general in nature and does not constitute legal advice. Furthermore, the use of this information, and the sending or receipt of this information, does not create or constitute an attorney-client relationship between us. Therefore, your communication with us via this information in any form will not be considered as privileged or confidential.
This information is not intended to be advertising, and Legal & Compliance, LLC does not desire to represent anyone desiring representation based upon viewing this information in a jurisdiction where this information fails to comply with all laws and ethical rules of that jurisdiction. This information may only be reproduced in its entirety (without modification) for the individual reader’s personal and/or educational use and must include this notice.
© Legal & Compliance, LLC 2016
Legal & Compliance, LLC Adds Lazarus Rothstein, Esq. as Of Counsel as Economic Confidence Builds in 2013 among its Clients
WEST PALM BEACH, FLORIDA (January 10, 2013) – Legal & Compliance, LLC is pleased to announce that Lazarus Rothstein, Esq. has recently joined the firm as Of Counsel to bring additional depth to its corporate and securities law practice. Mr. Rothstein has been a legal and business executive for a wide variety of public and private companies based in South Florida with worldwide operations.
Mr. Rothstein has held senior legal positions at CD International Enterprises, a company that produces pure magnesium in China and provides business and financial corporate consulting services; Elizabeth Arden, a global prestige fragrance and beauty products company with operations in over 17 countries; Sports Authority, the nation’s largest full-line sporting goods retailer, operating over 385 stores throughout the United States; Daleen Technologies, a billing and customer care software provider; and Let’s Talk Cellular & Wireless, a specialty retailer of wireless communication products and services that operated over 270 stores in the United States. In his role as a corporate lawyer, Mr. Rothstein has been responsible for Securities and Exchange Commission compliance and reporting, a variety of public debt and equity offerings and mergers and acquisitions. In addition, Mr. Rothstein has supported major business units of companies and clients in negotiating customer and product supply agreements, license, distribution, marketing, logistics and information technology agreements as well as expansion into the Pacific Rim market.
Mr. Rothstein received his Bachelor of Science degree in Accounting from Florida State University and his Juris Doctor degree from Nova Southeastern University Law School, and has received an AV rating from Martindale-Hubble, the highest level of professional excellence.
Laura Anthony, Esq., the founding member of Legal & Compliance, LLC comments, “I am excited to have ‘Laz’ join our team as we see an acceleration in our practice as economic confidence builds in 2013 among our clients. Bringing Laz on board enables us to meet the continuing growth needs of our clients and our firm.”
Legal & Compliance, LLC is a multifaceted corporate and securities law firm assisting clients in all aspects of commerce, including reverse mergers, registered public offerings, compliance with the over-the-counter market trading platforms such as OTCQB, compliance with FINRA and DTC, forming limited partnerships and partnership agreements, forming limited liability companies and operating agreements, strategic planning in response to unique management and ownership issues, and broad-scope legal services.
Laura Anthony, Esq. can be reached at LAnthony@legalandcompliance.com and Mr. Rothstein can be reached at Lrothstein@legalandcompliance.com for further information about our services.
OTC Market Groups Has Modified Its Alternative Reporting Standard Effective January 3, 2013
Background
Over the past few years, the historical “pinksheets” has undergone some major changes, starting with the creation of certain “tiers” of issuers and culminating in its refurbished website and new url “www.otcmarkets.com”. The www.otcmarkets.com divides issuers into three (3) levels: OTCQX; OTCQB and pinksheets.
Issuers on the OTCQX must be fully reporting and current in their reporting obligations with the SEC and also undergo a quality review by industry professionals. Issuers on the OTCQB must be fully reporting and current in their reporting obligations with the SEC but do not undergo additional quality review.
Issuers on the pinksheets are not required to be reporting with the SEC. However, such issuers are then further qualified based on the level of voluntary information provided to the www.otcmarkets.com. Issuers with no information are denoted by a skull and crossbones, Issuers with limited financial and business information are classified as “limited information and Issuers which provide information as set forth in the OTC Markets Pink Alternative Reporting Standard are denoted with a “current information” symbol. Effective January 3, 2013 OTC Markets modified its OTC Markets Pink Alternative Reporting Standard for current information status.
The New OTC Markets Pink Alternative Reporting Standard Guidelines
Effective January 3, 2013, OTC Markets has made changes to the OTC Markets Pink Alternative Reporting Standard for current information status in an effort to make it more accessible for more companies. OTC Markets has streamlined its disclosure guidelines to align them more closely with the SEC Rule 15c2-11 guidelines, to eliminate the requirement for an attorney letter where audited financial statements are provided and to reduce the requirement for attorney letters from every quarter to just once a year upon the filing of an annual report.
These changes will provide tremendous benefit for companies seeking to obtain current information status with OTC Markets. The prior Pink Alternative Reporting Standard was more analogous to an SEC registration statement than the SEC 15c2-11 guidelines. The streamlined disclosure will allow many more companies to provide current information, where they aren’t quite ready to provide the type of information required of a company subject to the SEC reporting requirements.
Moreover, the elimination of the attorney letter requirement for companies providing audited financial statements, and reducing the requirement for other entities, will likewise make the OTC Market’s current information status much more accessible. The OTC Markets attorney letter places a heavy burden on the attorney preparing the letter, to verify the information contained in the letter and conduct indepth due diligence on the Company. In cases where the Company has already incurred the expense of having audited financial statements prepared, the extra cost associated with a second, legal audit, proved onerous. Although attorneys that regular prepare these letters will see a reduction in fees, I believe that OTC Markets is correct in taking this approach, which recognizes that the burden of providing full and accurate disclosure lies with the Company and its officers and directors.
The Author
Laura Anthony, Esq.
Founding Partner
Legal & Compliance, LLC
Corporate, Securities and Going Public Attorneys
LAnthony@LegalAndCompliance.com
Securities attorney Laura Anthony and her experienced legal team provides ongoing corporate counsel to small and mid-size private companies, OTC and exchange traded issuers as well as private companies going public on the NASDAQ, NYSE MKT or over-the-counter market, such as the OTCQB and OTCQX. For nearly two decades Legal & Compliance, LLC has served clients providing fast, personalized, cutting-edge legal service. The firm’s reputation and relationships provide invaluable resources to clients including introductions to investment bankers, broker dealers, institutional investors and other strategic alliances. The firm’s focus includes, but is not limited to, compliance with the Securities Act of 1933 offer sale and registration requirements, including private placement transactions under Regulation D and Regulation S and PIPE Transactions as well as registration statements on Forms S-1, S-8 and S-4; compliance with the reporting requirements of the Securities Exchange Act of 1934, including registration on Form 10, reporting on Forms 10-Q, 10-K and 8-K, and 14C Information and 14A Proxy Statements; Regulation A/A+ offerings; all forms of going public transactions; mergers and acquisitions including both reverse mergers and forward mergers, ; applications to and compliance with the corporate governance requirements of securities exchanges including NASDAQ and NYSE MKT; crowdfunding; corporate; and general contract and business transactions. Moreover, Ms. Anthony and her firm represents both target and acquiring companies in reverse mergers and forward mergers, including the preparation of transaction documents such as merger agreements, share exchange agreements, stock purchase agreements, asset purchase agreements and reorganization agreements. Ms. Anthony’s legal team prepares the necessary documentation and assists in completing the requirements of federal and state securities laws and SROs such as FINRA and DTC for 15c2-11 applications, corporate name changes, reverse and forward splits and changes of domicile. Ms. Anthony is also the author of SecuritiesLawBlog.com, the OTC Market’s top source for industry news, and the producer and host of LawCast.com, the securities law network. In addition to many other major metropolitan areas, the firm currently represents clients in New York, Las Vegas, Los Angeles, Miami, Boca Raton, West Palm Beach, Atlanta, Phoenix, Scottsdale, Charlotte, Cincinnati, Cleveland, Washington, D.C., Denver, Tampa, Detroit and Dallas.
Contact Legal & Compliance LLC. Technical inquiries are always encouraged.
Follow me on Facebook, LinkedIn, YouTube, Google+, Pinterest and Twitter.
Download our mobile app at iTunes.
Legal & Compliance, LLC makes this general information available for educational purposes only. The information is general in nature and does not constitute legal advice. Furthermore, the use of this information, and the sending or receipt of this information, does not create or constitute an attorney-client relationship between us. Therefore, your communication with us via this information in any form will not be considered as privileged or confidential.
This information is not intended to be advertising, and Legal & Compliance, LLC does not desire to represent anyone desiring representation based upon viewing this information in a jurisdiction where this information fails to comply with all laws and ethical rules of that jurisdiction. This information may only be reproduced in its entirety (without modification) for the individual reader’s personal and/or educational use and must include this notice.
© Legal & Compliance, LLC 2016
The ABA Pushes To Allow For The Payment Of Finder’s Fees
In April of this year, the American Bar Association Private Placement Broker Task Force delivered to the SEC and published a recommendation for a limited federal exemption from SEC registration for securities intermediaries that would be able to assist in the private raise of capital for both private and public entities. The Task Force previously published a lengthy recommendation and even drafted proposed rules, in June 2005, and has been advocating the rules since that time. The full text of both the April 2012 submission and June 2005 report with proposed rules can be read on the SEC website.
The SEC’s Position and Current Rules on Finder’s Fees
The Securities and Exchange Commission (SEC) strictly prohibits the payments of commissions or other transaction based compensation to individuals or entities that assist in a capital raise, unless that entity is a licensed broker dealer.
Periodically, and most recently in April 2008, the SEC updates its Guide to Broker Dealer Registration explaining in detail the rules and regulations regarding the requirement that individuals and entities that engage in raising money for companies, must be licensed by the SEC as broker dealers. On a daily basis, hundreds if not thousands, of individuals and entities offer to raise money for companies as “finders” in return for a “finder’s fee.” Such agreements and transactions are prohibited and carry regulatory penalties for both the Company utilizing the finder’s services, and the finders.
Each of the following individuals and businesses are required to be registered as a broker if they are receiving transaction based compensation (i.e. a commission):
- “finders,” “business brokers,” and other individuals or entities that engage in the following activities:
- Finding investors or customers for, making referrals to, or splitting commissions with registered broker-dealers, investment companies (or mutual funds, including hedge funds) or other securities intermediaries;
- Finding investment banking clients for registered broker-dealers;
- Finding investors for “issuers” (entities issuing securities), even in a “consultant” capacity;
- Engaging in, or finding investors for, venture capital or “angel” financings, including private placements;
- Finding buyers and sellers of businesses (i.e., activities relating to mergers and acquisitions where securities are involved);
- investment advisers and financial consultants;
- persons that market real-estate investment interests, such as tenancy-in-common interests, that are securities;
- persons that act as “placement agents” for private placements of securities;
- persons that effect securities transactions for the account of others for a fee, even when those other people are friends or family members;
- persons that provide support services to registered broker-dealers; and
- persons that act as “independent contractors,” but are not “associated persons” of a broker-dealer (for information on “associated persons,” see below).
The SEC has been bringing actions against individuals and entities that violate these provisions and has indicating its intent to widen its enforcement efforts in this area.
An individual or entity may be able to collect compensation for acting as a finder as long as the compensation is not success or transaction based and the finder’s role is limited to making an introduction. The finder may not participate in negotiations, structuring or document preparation or execution.
An exception is that the federal securities laws do allow company officers, directors and employees to raise capital without being licensed as brokers. Company officers, directors and employees may engage in capital raising efforts, and receive compensation for their efforts, if such individuals: (i) are not subject to a statutory disqualification such as participation in securities activities for which they have been barred by a regulatory agency; (ii) the compensation is not a commission or other success based fee; (iii) the officer, director or employee performs, or is intended to perform at the end of the offering, substantial duties for or on behalf of the company otherwise than in connection with the offering; (iv) the officer, director or employee was not a broker or dealer, or an associated person of a broker or dealer, within the preceding 12 months; and (v) the officer, director or employee restricts his or her participation to any one or more of the following activities (a) preparing any written communication or delivering such communication through the mails or other means that does not involve oral solicitation by the officer, director or employee of a potential purchaser; Provided however, that the contents of such communication is approved by a partner, officer or director of the company; (b) responding to inquiries of potential purchaser in a communication initiated by the potential purchaser; Provided however, that the content of such responses are limited to information contained in a registration statement filed under the Securities Act of 1933 or other offering document; or (c) performing ministerial and clerical work involved in effecting any transaction.
The ABA’s Recommendation
The ABA is proposing an exemption from full broker dealer registration for what they are calling “securities intermediaries.” The ABA recognizes that the term “finder” carries a negative, if not illegal, connotation and thus the new terminology. Under the proposal, the securities intermediary would be exempt from full registration for such activities as arranging the purchase and sale of securities in private placements; making introductions to broker dealers and investment bankers; assisting in due diligence; deal structure; valuations and negotiating and obtaining financing.
The exemption, however, is only on the federal level. The SEC has indicated it would only consider the exemption if state regulators enacted a state registration regime. That is, securities intermediaries would be exempt from broker dealer registration and registration with the SEC (and therefore with FINRA) but would be required to register on the state level, in each state that they acted as a securities intermediary. Further, the SEC indicated it would also allow state registered finders or securities intermediaries to be compensated by FINRA members, a practice that is strictly prohibited today.
The ABA Task Force report believes that state registration will allow small companies to legally use intermediaries that are professional and somewhat regulated, to raise capital. The ABA proposes that the individual states set up a registration process, licensing requirements and procedures and examinations for securities intermediaries/finders. The SEC has indicated that a precondition would be bad actor qualifications, which is advocated in the ABA Task Force recommendation.
The Author
Laura Anthony, Esq.
Founding Partner
Legal & Compliance, LLC
Corporate, Securities and Going Public Attorneys
LAnthony@LegalAndCompliance.com
Securities attorney Laura Anthony and her experienced legal team provides ongoing corporate counsel to small and mid-size private companies, OTC and exchange traded issuers as well as private companies going public on the NASDAQ, NYSE MKT or over-the-counter market, such as the OTCQB and OTCQX. For nearly two decades Legal & Compliance, LLC has served clients providing fast, personalized, cutting-edge legal service. The firm’s reputation and relationships provide invaluable resources to clients including introductions to investment bankers, broker dealers, institutional investors and other strategic alliances. The firm’s focus includes, but is not limited to, compliance with the Securities Act of 1933 offer sale and registration requirements, including private placement transactions under Regulation D and Regulation S and PIPE Transactions as well as registration statements on Forms S-1, S-8 and S-4; compliance with the reporting requirements of the Securities Exchange Act of 1934, including registration on Form 10, reporting on Forms 10-Q, 10-K and 8-K, and 14C Information and 14A Proxy Statements; Regulation A/A+ offerings; all forms of going public transactions; mergers and acquisitions including both reverse mergers and forward mergers, ; applications to and compliance with the corporate governance requirements of securities exchanges including NASDAQ and NYSE MKT; crowdfunding; corporate; and general contract and business transactions. Moreover, Ms. Anthony and her firm represents both target and acquiring companies in reverse mergers and forward mergers, including the preparation of transaction documents such as merger agreements, share exchange agreements, stock purchase agreements, asset purchase agreements and reorganization agreements. Ms. Anthony’s legal team prepares the necessary documentation and assists in completing the requirements of federal and state securities laws and SROs such as FINRA and DTC for 15c2-11 applications, corporate name changes, reverse and forward splits and changes of domicile. Ms. Anthony is also the author of SecuritiesLawBlog.com, the OTC Market’s top source for industry news, and the producer and host of LawCast.com, the securities law network. In addition to many other major metropolitan areas, the firm currently represents clients in New York, Las Vegas, Los Angeles, Miami, Boca Raton, West Palm Beach, Atlanta, Phoenix, Scottsdale, Charlotte, Cincinnati, Cleveland, Washington, D.C., Denver, Tampa, Detroit and Dallas.
Contact Legal & Compliance LLC. Technical inquiries are always encouraged.
Follow me on Facebook, LinkedIn, YouTube, Google+, Pinterest and Twitter.
Download our mobile app at iTunes.
Legal & Compliance, LLC makes this general information available for educational purposes only. The information is general in nature and does not constitute legal advice. Furthermore, the use of this information, and the sending or receipt of this information, does not create or constitute an attorney-client relationship between us. Therefore, your communication with us via this information in any form will not be considered as privileged or confidential.
This information is not intended to be advertising, and Legal & Compliance, LLC does not desire to represent anyone desiring representation based upon viewing this information in a jurisdiction where this information fails to comply with all laws and ethical rules of that jurisdiction. This information may only be reproduced in its entirety (without modification) for the individual reader’s personal and/or educational use and must include this notice.
© Legal & Compliance, LLC 2016