Month: November 2008

A previous post in this occasional series on the new Enforcement Manual considered its discussion of the Wells Process (discussed here). Another key section discusses “cooperation credit,” considered in Section 4.3 and titled “Waiver of Privilege.” Perhaps the most striking …

The New Enforcement Manual And Cooperation Read More »

The SEC settled with two of the six defendants in its two-year old case against six former officers of Putnam Fiduciary Trust Company, a Boston based transfer agent. The complaint, initially filed in 2006, alleged that the defendants’ violated Securities …

SEC Settles With Two of Six Former Putnam Employees Read More »