Year: 2015

The Disqualification Provisions and the SEC’s Use of Wavers

One key debate regarding current SEC enforcement policy centers on the application of the so-called “bad actor” provisions. Previously the Commissioners split over the nature, use and application of those provisions. Central to the debate is whether the application of

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This Week In Securities Litigation (Week ending March 13, 2015)

The SEC filed one new action this week – an administrative proceeding involving the principal of an investment adviser and undisclosed conflicts of interest. The Commission also amended a complaint in an insider trading action, adding an additional defendant in

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