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Richard J. Busis

Of Counsel
P (215) 665-2756

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      Securities

      The post-millennial economy has experienced turmoil and transformation, but one fact remains unchanged: U.S. capital markets are essential. America has the most credible and efficient markets in the world and the flow of capital through them drives global economic productivity. It is also true that, since 2000, capital-market overseers have unleashed waves of new regulations in response to various market failures. In order to participate in this most desirable of markets, businesses must absorb and abide complicated legal strictures. Now more than ever, clients need counsel who can help them get in and stay in the capital markets.

      Cozen O’Connor’s global securities group serves a wide array of corporate clients in the U.S., Europe, South and Central America, Australia and Asia. We work with public and private companies, officers and directors, investors, registered broker-dealers and stock exchanges. We advise these clients on federal and state securities laws, stock exchange rules, and Financial Industry Regulatory Authority (FINRA) requirements, and provide counsel on all types of capital markets transactions, from initial public offerings and stock exchange listings to at-the-market offerings, (ATMs), private into public private offerings (PIPEs), shelf takedowns, reverse mergers, mergers and tender offers. Moreover, the group defends clients in securities investigations, controversies and litigation.

      Securities is an unusual practice in part because the regulation scheme is largely administrative, rather than statutory. This means that it is absolutely critical for counsel to have good relationships with and access to public officials. Cozen O’Connor’s team has been working closely with high-level officials at the SEC, national exchanges, FINRA, and Public Company Accounting Oversight Board for nearly thirty years. Our attorneys have a reputation among key decision makers for being knowledgeable and forthright, which means our requests for review, relief, or assistance are greeted with a well-earned presumption of legitimacy.

      Cozen O’Connor also differentiates itself through it’s staffing method, which rejects the high-leverage model used by most large law firms. Instead of forcing our most seasoned attorneys to supervise large teams of inexperienced associates, we free senior members to actually practice law. Two things happen when veteran lawyers are directly involved in every aspect of the work: projects are completed more efficiently because there is less need for review and revision, and legal argumentation is more sophisticated because it is crafted by attorneys with a nuanced understanding of securities law and business imperatives.

      Not only do our senior securities attorneys serve clients directly, they serve clients around the clock. New York is five hours behind London, eleven hours behind Beijing and Tokyo and fourteen hours behind Australia, which means there is continual activity in the capital markets. This practice group is designed to operate twenty-four hours a day so that attorneys are available to provide tactical advice to clients whenever they need it.

       

      SERVICES

      Regulatory

      • Advise clients on compliance with all securities laws, including the Securities Act of 1933, Securities and Exchange Act of 1934, Trust Indenture Act of 1939, Investment Advisors Act of 1940, Bank Secrecy Act, Foreign Corrupt Practices Act, National Securities Markets Improvements Act, Sarbanes-Oxley, Dodd-Frank, the JOBS Act, NSMIA and Blue Sky laws
      • Create public and private corporations, limited liability companies, and partnerships or trusts
      • Counsel companies, partnerships, broker-dealers, investment advisors, investment companies, boards and committees, and individuals on securities matters
      • Assist with periodic public reports, annual reports to shareholders, and proxy materials

      Transactional

      • Perform first time listings, initial public offerings (IPOs), re-IPOs, alternative public offerings (APOs), and reverse mergers
      • Negotiate shelf takedowns
      • Counsel on ATM and equity line offerings and secondary underwritten offerings, private placements, PIPEs, and Rule 144A/Regulation S offerings
      • Conduct spin-offs, split-offs, and carve-out transactions
      • Support senior, subordinated, secured, and unsecured debt offerings, as well as high-yield and investment-grade debt offerings
      • Advise on public auctions, tender offers, and privatizations

      Controversy and Litigation

      • Defend clients in delisting proceedings before securities exchanges such as NASDAQ, NYSE Amex, and other entities
      • Represent clients in examinations, inspections, informal and formal investigations, and enforcement proceedings brought by the U.S. Securities and Exchange Commission, FINRA, securities exchanges, and state “Blue Sky” authorities
      • Defend clients in administrative proceedings brought by the SEC, FINRA, state securities agencies, and stock exchanges
      • Defend clients in civil and criminal securities cases, including securities class action and derivative suits

       

      CLIENTS

      • Private and public companies
      • Institutional investors
      • Investment and hedge funds
      • Special purpose acquisition companies (SPACs)
      • Board of directors and special/standing committees, including audit committees, governance committees, compensation committees and special litigation committees
      • Officers and directors
      • Broker-dealers and investment bankers
      • Investment advisers

       

      TEAM

      The securities team operates out of several offices, including the regulatory and transactional hubs of Washington D.C., New York City and Philadelphia, which means that when matters demand quick action, our attorneys are already on location. Cozen O’Connor attorneys have top legal and academic credentials, as well as prior governmental and corporate experience. The team includes a former COO of the Treasury Department’s $700-billion Troubled Asset Relief Program, member of the SEC’s Enforcement Division, currency trader, bank officials, and in-house attorneys. Attorneys in the group are frequently asked to provide comment and background on securities law and related compliance matters. 

      This practice group serves companies ranging in size from venture capital startups to Fortune 500 enterprises, but we are particularly well known for our work with small- to mid-cap public companies and regional brokers. This so-called “middle market” is actually growing faster, producing more jobs, and attracting more capital than any other segment of the U.S. economy. Such dynamic companies need securities lawyers who see their potential, are attuned to their specific challenges, and are willing to make a long-term commitment to their expansion. Due to Cozen O’Connor’s history of entrepreneurship, our attorneys are ideally positioned to provide the combination of legal and business support that growing companies require.

      Experience

      Represented investment bankers in a $115 million initial public offering of stock for the Shanghai Century Acquisition Corp.


      Represented the issuer in connection with a private placement of $10 million of preferred stock. The issuer is in business services. The funds were used for an acquistion and working capital.


      Represented several individual clients who purchased a large amount of auction rate securities (ARS). Subsequently, when the credit crunch hit and the ARS market seized up, our clients were left with sizable illiquid assets. Previous ARS claims had been framed as standard securities frauds. Our litigators devised a strategy to file common law claims alleging negligent misrepresentation, breach of fiduciary duty, and unfair trade practices. The claims survived a motion to dismiss and a motion for summary judgment. Shortly after the start of the trial, the case settled to our clients’ satisfaction.


      Attorneys

      Richard J. Busis Of Counsel Philadelphia (215) 665-2756
      Mark M. Dugan Associate Philadelphia (215) 665-2191
      Anne M. Madonia Member Philadelphia (215) 665-7259
      David S. Nelson Member Philadelphia (215) 665-2000
      Patrick J. O´Connor Vice Chairman West Conshohocken (610) 941-2375
      Tracy Sheridan Reyle Member Philadelphia (215) 665-4665
      Jason M. Shargel Member Philadelphia (215) 665-6914

      Publications


      SEC Recommends Major Changes in Municipal Securities Market [Public & Project Finance Alert]

      October 01, 2012

      MORE


      GAO Publishes Report on Factors That May Affect Trends in Regulation A Offerings [Securities Alert]

      July 19, 2012

      MORE


      The JOBS ACT: SEC Guidance on the Changes to the Registration and Deregistration Requirements under the Exchange Act [Securities Alert]

      July 02, 2012

      MORE


      Confidentiality Agreements and Standstill Provisions; the Delaware Chancery Court Broadly Construes Confidentiality Agreements and Enjoins a Hostile Bid Despite the Absence of Standstill Provisions Relating to Stock Transactions [Securities Alert]

      June 26, 2012

      MORE


      The JOBS Act: SEC Guidance on the Confidential Submission Process [Securities Alert]

      May 10, 2012

      MORE


      SEC Approves Nasdaq Proposal for Alternative Minimum Bid Price Listing Requirement [Securities Offerings and Regulation Alert!]

      May 07, 2012

      MORE


      JOBS Act Becomes Law and SEC Issues Guidance: The JOBS Act Reforms the Regulatory Scheme Governing the Offering of Securities [Securities Offerings and Regulation Alert!]

      April 13, 2012

      MORE


      Supreme Court Decision Limits Scope of Private Securities-Fraud Actions [Securities Offerings and Regulation Alert!]

      June 13, 2011

      MORE


      FINRA adopts regulations to address allocation, pricing and trading of new issues [Thomas Reuters]

      April 26, 2011

      MORE


      FINRA Adopts New Regulations to Address the Allocation, Pricing and Trade of New Issues [Securities Offerings and Regulation Alert!]

      April 08, 2011

      MORE


      FINRA Proposes Amendments to the Rule Governing Member Firm Participation in Private Placements [Securities Offerings and Regulation Alert!]

      March 02, 2011

      MORE


      SEC Proposes Rule to Define 'Family Office' [Securities Offerings and Regulation Alert!]

      November 16, 2010

      MORE


      SEC Proposes Say-On-Pay Rules [Securities Offerings and Regulation Alert!]

      November 16, 2010

      MORE


      The Second Circuit Issues an Important Decision Regarding the Scope of the Bespeaks-Caution Doctrine [Securities and Financial Services Litigation and Securities Regulation Alert!]

      September 29, 2010

      MORE


      Supreme Court Addresses the Constitutionality of Public Company Accounting Oversight Board... [Securities Offerings and Regulation Alert!]

      July 07, 2010

      MORE


      U.S. Supreme Court Addresses the Statute of Limitations for Private Federal Securities Fraud Claims [Securities Offerings and Regulation Alert!]

      May 21, 2010

      MORE


      FinCEN and Six Other Federal Regulators Issue Joint Guidance on Anti-Money Laundering Compliance [Securities Offerings and Regulations Alert!]

      April 20, 2010

      MORE


      First Circuit Dismisses SEC's Theory of Liability Under Rule 10b-5(b) for Underwriters [Securities Offerings and Regulations Alert!]

      March 18, 2010

      MORE


      SEC Proposes Amendments to Rule 10b-18 Safe Harbor for Issuer Repurchases [Securities Offerings and Regulations Alert!]

      March 02, 2010

      MORE


      SEC Adopts Short Sale Price Restrictions [Securities Offerings and Regulations Alert!]

      March 01, 2010

      MORE


      SEC Approves Amendments to NYSE Rule 452 [Securities Offerings and Regulations Alert!]

      October 06, 2009

      MORE


      SEC Proposes Amendments to the Investment Advisers Act Custody Rule [Securities Offerings and Regulations Alert!]

      September 24, 2009

      MORE


      SEC Director of Enforcement Discusses Changes Within the Division [Securities Offerings and Regulations Alert!]

      August 17, 2009

      MORE


      FINRA's Trade Reporting Rule Amendments Become Effective [Securities Offerings and Regulations Alert!]

      August 07, 2009

      MORE


      SEC Makes Short Sale Close-Out Rule Permanent [Securities Offerings and Regulations Alert!]

      August 05, 2009

      MORE


      Federal Appeals Court Orders SEC to Reconsider Rule 151A Addressing Fixed Indexed Annuities [Securities Offerings and Regulations Alert!]

      July 24, 2009

      MORE


      nst Mavericks' Cuban Dismissed; Misappropriation Theory of Insider Trading Questioned [Securities Offerings and Regulations Alert!]

      July 23, 2009

      MORE


      The State Of Unregistered Intermediary Regulation [Law 360]

      December 03, 2008

      MORE


      SEC Emergency Orders Related to Short Sales Clarified [Securities Offerings and Regulations Alert!]

      October 13, 2008

      MORE


      SEC Proposes Amendments to the Foreign Broker-Dealer Registration Exemptions in Rule 15A-6 [Securities Offerings and Regulations Alert!]

      September 05, 2008

      MORE


      SEC to Replace Edgar with "IDEA" [Securities Offerings and Regulations Alert!]

      August 28, 2008

      MORE


      SEC Further Extends Deadline For Non-Accelerated Filers' Compliance With Auditor Attestation Report Requirements of Section 404(b) of Sox [Securities Offerings and Regulations Alert!]

      July 14, 2008

      MORE


      Recent Court and SEC Actions Suggest Heightened Scrutiny for Finders [Securities Offerings and Regulations Alert!]

      July 08, 2008

      MORE


      FINRA Proposes New Rule to Govern Private Placements [Securities Offerings and Regulations Alert!]

      July 07, 2008

      MORE

      Events & Seminars

      AICPA Conference on Current SEC and PCAOB Developments Washington, DC 12/05/2012
      HB Litigation Conferences: The 17th Annual Insurance Insolvency & Reinsurance Roundtable Scottsdale, AZ 03/24/2010
      Malta – A New European Jurisdiction for Investment and Financial Business New York, NY 09/24/2009

      In The News


      West Palm Attorneys Levine, Dickenson, Criscuolo Favorably Settle Securities Case

      April 01, 2013

      MORE


      Cozen O’Connor Earns Client Recognition in 2010 Chambers USA Rankings

      June 18, 2010

      MORE

      Related Practice Areas

      Business/Corporate

      China Practice

      Corporate

      Mergers & Acquisitions

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