Published Works

How to Avoid a Product that Nobody Wants

By Christopher D. Warren / August 31, 2020
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Today’s blog post focuses on the most cited of the reasons why start ups fail: a lack of consumer interest in the product or service the business intends to provide. Every new parent’s baby is the cutest they’ve ever seen, and every start up entrepreneur starts out thinking their proposed product or service is a…

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So You Want to Start a Start Up…

By Christopher D. Warren / August 31, 2020
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Introduction Welcome to the “So You Want to Start a Start Up…” blog! I’m Paul Share, and I, along with my colleague Todd Kulkin, have been working with start ups for over 30 years. We’ve started this blog to provide you with the benefit of our experience on some of the legal and business issues…

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Raising Capital? Avoid Pitfalls of a Private Placement

By Christopher D. Warren / August 19, 2020
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Recently, federal securities regulators accused six people of deceiving investors in connection with unregistered securities offerings for a supposed marijuana farm and CBD extraction facility in California. Allegedly, the defendants raised $25 million from more than 400 investors from across the country promising huge returns of 100% or more. At the core of the case,…

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How to Answer a FINRA Rule 8210 Inquiry

By Christopher D. Warren / July 31, 2020
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So, you got a letter. From FINRA. It’s about an examination. It’s a Rule 8210 letter. Now what? When you get a Rule 8210 letter from FINRA, it’s serious. This letter is telling you FINRA is launching an investigation, which you, as a registered person of FINRA, are – in some way, shape, or form…

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Securities Law: What Investment Advisors Need to Know About New SEC Limits on Disgorgement

By Christopher D. Warren / July 23, 2020
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On June 22, 2020, a ruling by The U.S. Supreme Court placed new limits on the Securities and Exchange Commission’s (SEC’s) practice around disgorgement – which forces defendants to surrender profits obtained through fraud as part of its enforcement of investor-protection laws in federal courts. According to the ruling, while the SEC can continue to…

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Global Pandemic or Not, Regulation BI is Here – Here Is FINRA’s Guidance

By Christopher D. Warren / July 10, 2020
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Despite the devastating effects of the Covid-19 pandemic on the country and the economy, on June 30, 2020, the United States Securities and Exchange Commission (“SEC”) chose to move forward and implement Regulation Best Interest (“Reg BI”), under the Securities Exchange Act of 1934. Shortly, thereafter, the Financial Industry Regulatory Authority (“FINRA”) issued its own…

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