Month: May 2009

The SEC is at a cross roads. While it is clear that the market crisis is going to have a significant effect on the Commission, its precise impact is yet to be determined. Key events are still unfolding. The roots …

Part X: SEC Enforcement Trends, 2009 — Analysis And Conclusion Read More »

Earlier this year, the First Circuit Court of Appeals defined the scope of aiding and abetting liability in an SEC enforcement action. In SEC v. Papa, Case No. 08-1172 (1st Cir. Decided Feb. 6, 2009), the court rejected the SEC’s …

The Test Of Primary Liability In An SEC Enforcement Action Read More »