Bradley J. Bondi, Charles A. Gilman, Kimberly C. Petillo-Décossard, John J. Schuster and Sara Ortiz
To explain a recent US Securities and Exchange Commission (SEC) administrative proceeding targeting a broker-dealer as part of the Commission’s continuing efforts to enforce…
Abstract
Purpose
To explain a recent US Securities and Exchange Commission (SEC) administrative proceeding targeting a broker-dealer as part of the Commission’s continuing efforts to enforce anti-money laundering (AML) regulations and reporting.
Design/methodology/approach
This article explores the factual and legal contours of a specific SEC administrative proceeding to better understand the affirmative steps the Commission expects of financial service providers as it relates to AML activities and reporting.
Findings
Given the SEC’s current enforcement focus, it is critical that financial institutions conduct their activities with a clear understanding of the AML regulations, investigatory expectations and related reporting requirements associated with the provision of brokerage and advisory services to US clients and customers.
Originality/value
This article highlights the SEC’s continuing interest in broker-dealer AML policies and compliance and provides analysis from experienced lawyers with expertise in financial services, securities and white collar crime.
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Keywords
Helene R. Banks, Bradley J. Bondi, Charles A. Gilman, Elai Katz, Geoffrey E. Liebmann, Ross Sturman and Nicholas S. Millington
To explain the rule changes in Nasdaq’s new Listing Rule IM-5315-1, approved by the US Securities and Exchange Commission (SEC) on February 15, 2019, that permit direct listings…
Abstract
Purpose
To explain the rule changes in Nasdaq’s new Listing Rule IM-5315-1, approved by the US Securities and Exchange Commission (SEC) on February 15, 2019, that permit direct listings on Nasdaq without an initial public offering, similar to the New York Stock Exchange (NYSE) rule changes approved in 2018.
Design/methodology/approach
Explains the legislative and regulatory background, historic limitations on direct Nasdaq listings, and de-tailed provisions of Nasdaq’s new Listing Rule IM-5315-1.
Findings
The direct listing alternative to an IPO may appeal to cash-rich companies that do not need the publicity or new capital associated with a traditional IPO.
Originality/value
Expert analysis from experienced securities litigation and corporate governance lawyers.
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Bradley J. Bondi, David Slovick and Michael Wheatley
To provide an overview of the Commodity Futures Trading Commission’s (CFTC’s) new self-reporting and cooperation program.
Abstract
Purpose
To provide an overview of the Commodity Futures Trading Commission’s (CFTC’s) new self-reporting and cooperation program.
Design/methodology/approach
Summarizes the key features of the CFTC’s new cooperation program and the CFTC’s statement of its purpose in enacting the program; provides the authors’ views on the likely implications of the program for CFTC enforcement actions.
Findings
Whether the CFTC’s self-reporting and cooperation program will be a useful tool for deterring misconduct remains to be seen as the CFTC begins to implement it, but there are indications that it may encourage cooperation. If properly implemented, the program has the potential to benefit the CFTC and regulated parties significantly.
Originality/value
Practical insights on a new CFTC policy from experienced civil enforcement lawyers.
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Kelly Farley, Rick Walker, Harry Bondy and Dan Mendoza
Unlike many militaries in Europe, the Canadian Forces (CF) have no union or representative association. Although two separate studies have shown that more than one-third of…
Abstract
Unlike many militaries in Europe, the Canadian Forces (CF) have no union or representative association. Although two separate studies have shown that more than one-third of military members think positively about forming a union (Bradley & Charbonneau, 2004; Deneumoustier, 1971), there has traditionally been little movement towards any form of associationism within Canada's military. While there is no formal ‘contract’ between the CF and the government of Canada, an informal social contract has appeared to be successful in maintaining the status quo. Critics of the social contract argue the agreement is one-sided; that is, the responsibilities of the member to Canada are well defined in the National Defence Act and Queen's Regulations and Orders but there is “no such articulation of the responsibilities of the Government of Canada to the men and women of the CF” (Milner, 1998, p. 10).
Robert C. Pennington, Monique Pinczynski and Kathryn Davis
Students with extensive supports needs (ESN) often require pervasive and intensive supports to access the full benefits of educational programming. In this chapter, the authors…
Abstract
Students with extensive supports needs (ESN) often require pervasive and intensive supports to access the full benefits of educational programming. In this chapter, the authors describe the application of both established and innovative technologies for promoting equitable access and opportunity for these students. They provide guidance for the use of technology across the areas of academic instruction, social communication, behavior supports, daily living, and employment.
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Shannon Stuart and Kris Van Handel
This chapter presents ways in which educators can use technology to enhance learning for students with autism spectrum disorder (ASD). The chapter begins with an overview of the…
Abstract
This chapter presents ways in which educators can use technology to enhance learning for students with autism spectrum disorder (ASD). The chapter begins with an overview of the communicative and social challenges that students with ASD typically experience. Next, it defines technology-aided instruction and intervention (TAII) and offers suggestions for educators planning to incorporate TAII into their classroom. The third section offers specific supports on using TAII to enhance communication while the final section offers specific supports on using TAII to enhance affective and social learning. Case studies and tables with clearly defined supports are included throughout the chapter. Educators may combine the supports presented because each support addresses more than one characteristic or need. In addition, educators will find that these supports benefit students with neurodiverse learning needs who may not be identified with ASD.
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Emily C. Bouck and Courtney Maher
The term intellectual disability is broad and encompassing. Regardless of the severity of a child’s intellectual disability, early education is important. This chapter discusses…
Abstract
The term intellectual disability is broad and encompassing. Regardless of the severity of a child’s intellectual disability, early education is important. This chapter discusses educational considerations of young learners with intellectual disability. Specially, the chapter focuses on academics, life skills, social skills and social development, and behavior. Instructional content and instructional strategies are shared for these areas considering young children, although particular attention in paid to preschool and early elementary age students.
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Oliver James Bradley and Gloria Oforiwaa Botchway
The purpose of this paper is to identify the sustainability indicators disclosed by ten British Coffee Association corporate members in their sustainability reporting and examine…
Abstract
Purpose
The purpose of this paper is to identify the sustainability indicators disclosed by ten British Coffee Association corporate members in their sustainability reporting and examine whether the indicators correspond to the sustainability challenges faced by the coffee industry, as identified in the literature.
Design/methodology/approach
A normative account of sustainability challenges was developed based on a review of extant literature. A content analysis of the sustainability reports and/or Webpages of the companies was conducted to identify quantitative and qualitative sustainability indicators. Frequency and thematic analysis enabled the subsequent examination.
Findings
A total of 94 sustainability indicators (44 environmental, 30 social and 20 economic) were identified in company reporting. The indicators correspond to the sustainability challenges identified in the literature. In addition to broad challenges, indicators are used to communicate specific issues. A significant number (47) of single-use indicators were identified, communicating less frequently reported challenges. Some companies account for sustainability from bean to cup, attributed to crucial differences in organisational characteristics (degree of vertical integration). Furthermore, the findings highlight the discretionary nature of sustainability reporting, finding considerable variance in indicators disclosed.
Research limitations/implications
As this paper relies on self-reported corporate disclosures, it critically examines the reporting practices of organisations, as opposed to verifying the activities associated with their claims. The authors minimised subjectivity by reducing the interpretation of what constituted “an indicator” using a clearly agreed definition and multiple rounds of coding.
Practical implications
This paper examines the reporting practices of organisations, providing a useful insight and a competitor benchmark. By comprehensively examining the sustainability challenges faced by the coffee industry, it offers “sustainability context” that can be used by organisations to improve their accounting and reporting practices.
Social implications
This paper acknowledges and addresses social initiatives that call for the systematic development of practical and appropriate sustainability indicators that can become embedded in policy and decision-making, affecting the measurement of progress and responses to important sustainability challenges.
Originality/value
This paper presents the first systematic review of sustainability indicator disclosure in an industry that faces significant sustainability challenges.