Tag: disgorgement

During the current partial government shutdown when few SEC Enforcement actions are being filed or settled it may be a good time to begin considering the future of the program. The Division has repeatedly announced that its focus is retail …

The Future Course of SEC Enforcement Read More »

Tagged with: , , , , , , , ,

One of the guiding principles of the current SEC Enforcement program is to “Impose Sanctions That Most Effectively Further Enforcement Goals.” SEC Division of Enforcement Annual Report 2017. Yet just months prior to the issuance of that Report, the Supreme …

SEC Disgorgement: A Path For Reform? Read More »

Tagged with: , ,