The Complaint provides screenshots from websites that appear to show an individual attempting to profit from deceiving unsophisticated investors as to opportunities in companies having cures for coronavirus. It is worth taking a quick look at the Complaint to see these presumably fraudulent advertisements.

Firms would be well advised to review FINRA's "suggestions" as to the conduct of supervisory procedures during the current work-from-home period. While one would expect the regulators to grant firms some leeway on the details, the regulators have not granted firms any general exemption from their supervisory obligations. (See also .)

The U.S. regulators have issued similar warnings to corporate and public issuers as to the quality of their disclosures.  See, e.g.  and .

ICA Section 18(i) states as follows:

"[Subject to certain exceptions] every share of stock hereafter issued by a registered management company . . . shall be a voting stock and have equal voting rights with every other outstanding voting stock."

Read literally, it is not obvious that the Boulder Letter reached a wrong conclusion as to the words of the ICA. However, according to a footnote in the statement by the Division of Investment Management.