It is axiomatic firms must disclose of material information that is complete and accurate. Thus, for example, when the president of a regulated entity speaks to investors regarding communications with the firm’s regulator, it is critical that the information about … Director Fails to Disclose FDA Orders Halting Two Drugs Read More »
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This Week In Securities Litigation (Week of December 2, 2024)
Last week as many celebrated Thanksgiving the Commission filed three new enforcement actions. One focused on Rule 105 compliance, a second on muni registration and a third on an offering fraud. Be careful, be safe this week SEC Enforcement – … This Week In Securities Litigation (Week of December 2, 2024) Read More »
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Happy Thanksgiving!
Cooperation and Its Impact
The impact of cooperation on a Commission investigation can be difficult to assess. The agency has long espoused cooperation as a way to mitigate the ultimate resolution of an investigation and any possible sanctions. The agency typically acknowledges the impact … Cooperation and Its Impact Read More »
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This Week In Securities Litigation (Week of November 25, 2024)
The Commission filed a series of new cases last week. The filings included an action based on cherry picking, one focused on international banking and bribery in violation of the FCPA, another centered on a manipulation scheme and a case … This Week In Securities Litigation (Week of November 25, 2024) Read More »
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Adviser Operating Cherry Picking Scheme Makes over $1.8 million
Cherry picking is a long time focus of the Commission. In some senses, this practice may the be ultimate conflict of interest. It is based on an investment adviser placing a series of trades over the course of the trading … Adviser Operating Cherry Picking Scheme Makes over $1.8 million Read More »
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Misappropriation, Conflicts And Illegal Stock Sales
Conflicts of interests and sham transactions are a key consideration when dealing with issues involving the federal securities laws. Many of the cases initiated by the Commission center on conflicts such as those that can arise when a controlling shareholder … Misappropriation, Conflicts And Illegal Stock Sales Read More »
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This Week In Securities Litigation (Week of November 18, 2024)
Last week the Commission filed four new enforcement actions. They were centered on Reg. BI, insider trading, a note scheme and an accounting fraud. Be careful, be safe this week SEC SEC Enforcement – Filed and Settled Actions Statistics: Last … This Week In Securities Litigation (Week of November 18, 2024) Read More »
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This Week In Securities Litigation (Week of November 11, 2024)
The Commission filed only one new case last week. It focused on false statement made by an investment adviser regarding references to ESG in discussions regarding the management of funds and investments. The advisory appeared to have no standards regarding … This Week In Securities Litigation (Week of November 11, 2024) Read More »
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