Tag: venue

The Future Course of SEC Enforcement

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

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SEC Enforcement & Venue: A Question of Fairness

The question never really addressed, but which has always been the fundamental issue, is fairness. When the Commission began shifting its enforcement actions from federal district court to its administrative in-house forum, the bedrock question was fundamental fairness, presented in

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