The Commission periodically has filed enforcement actions against broker-dealers for failing to file SARs – suspicious activity reports — typically centered on a failure to file reports regarding microcap issuers. Those actions are based on Exchange Act Section 17(a) and …

The SEC and SARs Read More »

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The Fifth Circuit Court of Appeals rejected another challenge to the constitutionality of the Commission’s ALJs. The claim turned on whether those judges are unconstitutionally protected from removal. In a 2-1 decision the Court adopted the position of DOJ, representing …

This Week In Securities Litigation (Week of August 17, 2020) Read More »

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