Securities Law Prof Blog

Editor: Eric C. Chaffee
Univ. of Toledo College of Law

Tuesday, December 11, 2012

SEC Charges Consultant with Fraud For Role in Chinese Firms' Reverse Mergers

The SEC charged Huakang “David” Zhou, a New Jersey-based consultant, with violating securities laws and defrauding some investors while helping Chinese companies gain access to the U.S. capital markets. According to the SEC, Zhou and his consulting firm Warner Technology and Investment Corporation located more than 20 private companies in China to bring public in the U.S. through reverse mergers and committed various securities laws violations in the course of advising those companies and later assuming operational roles at some of them.  After earning millions of dollars in consulting fees, Zhou and his firm have left several failed Chinese companies in their wake in the U.S. markets including China Yingxia International, whose registration was revoked after the company collapsed amid fraud allegations.  The SEC has previously charged several individuals and firms with misconduct related to China Yingxia, including Zhou’s son.

The SEC alleges that the elder Zhou engaged in varied misconduct ranging from non-disclosure of certain holdings and transactions to outright fraud.  For instance, Zhou failed to disclose to investors in one company that he engaged in questionable wire transfers of their money to evade Chinese currency regulations, and he orchestrated an elaborate scheme to meet the requirements necessary to list a purported Chinese real estate developer on a national securities exchange.  Zhou also stole $271,500 in investment proceeds from a capital raise to make mortgage payments on a million-dollar condo where his son lives in New York City. 

According to the SEC’s complaint filed in U.S. District Court for the Southern District of New York, Warner Technology and Investment Corporation advertises itself on its website as the first U.S. consulting firm that successfully brought a Chinese private company public in the U.S. through a reverse merger with an OTCBB trading company.  Zhou’s misconduct occurred from at least 2007 to 2010.  After completing the reverse mergers, Zhou strongly influenced or even directed many of his clients’ newfound U.S. presence and obligations as public companies.  He opened and controlled U.S. bank accounts for many of his clients to pay for services rendered and receive any proceeds from fundraising done in the U.S.  This enabled Zhou to control how and when offering proceeds were wired to China, and gave him the ability to direct money to himself purportedly to collect fees or repay loans made to the companies.


December 11, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

SEC Charges Fund Manager with Illegal Trading to Benefit Fund

The SEC charged Steven B. Hart, a New York-based fund manager, with conducting a pair of illegal trading schemes to financially benefit his investment fund Octagon Capital Partners LP.  The SEC alleges that Hart made $831,071 during a four-year period through illicit trading while he also worked as a portfolio manager and employee at a New Jersey-based firm that served as an adviser for several affiliated investment funds.  In one scheme, Hart illegally matched 31 pre-market trades to benefit his own fund at the expense of one of his employer’s funds.  In the other scheme, Hart conducted insider trading in the securities of 19 issuers based on nonpublic information he learned in advance of their offering announcements. Furthermore, Hart signed two securities purchase agreements in which he falsely represented that he had not traded the issuer's securities prior to the public announcement of the offerings in which he had been confidentially solicited to invest.

Hart agreed to pay more than $1.3 million to settle the SEC’s charges.


December 11, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

National Business Law Scholars Conference: Call for Papers

The 2013 National Business Law Scholars Conference (NBLSC)  will be held on Wednesday, June 12th and Thursday, June 13th at The Ohio State University Michael E. Moritz College of Law in Columbus, Ohio.  This is the fourth annual meeting of the NBLSC, a conference which annually draws together dozens of legal scholars from across the United States and around the world.  We welcome all on-topic submissions and will attempt to provide the opportunity for everyone to actively participate.  Junior scholars and those considering entering the legal academy are especially encouraged to participate. 

To submit a presentation, email Professor Eric C. Chaffee at [email protected] with an abstract or paper by April 15, 2013.  Please title the email “NBLSC Submission – {Name}”.  If you would like to attend, but not present, email Professor Chaffee with an email entitled “NBLSC Attendance”.  Please specify in your email whether you are willing to serve as a commentator or moderator.  A conference schedule will be circulated in late May.

Conference Organizers:

Barbara Black (University of Cincinnati)
Eric C. Chaffee (University of Dayton)
Steven M. Davidoff (The Ohio State University)

December 11, 2012 in Professional Announcements | Permalink | Comments (0) | TrackBack (0)

Monday, December 10, 2012

PCAOB Concerned About Deficiencies in Audits of Internal Controls over Financial Reporting

The Public Company Accounting Oversight Board today released a report summarizing inspection observations related to deficiencies in registered public accounting firms' audits of the internal control over financial reporting (ICFR) at public companies.  The report, "Observations from 2010 Inspections of Domestic Annually Inspected Firms Regarding Deficiencies in Audits of Internal Control over Financial Reporting," provides information about the nature and frequency of deficiencies in firms' audits of internal control over financial reporting detected during the PCAOB's 2010 inspections of eight domestic registered firms that have been inspected every year since the PCAOB inspection program began.

The report is based on PCAOB inspections that examined portions of approximately 300 such audits. It describes the most pervasive deficiencies identified in those audits and also includes information on the potential root causes of the deficiencies.

According to the Executive Summary:

The Board is concerned about the number and significance of deficiencies identified in firms' audits of internal control during the 2010 inspections, which generally involved reviews of the integrated audits of financial statements and internal control ("integrated audits") for issuers' fiscal years ending in 2009. This report describes the most pervasive deficiencies identified in firms' auditing of internal control during the 2010 inspections, and also includes information on the potential root causes of the deficiencies. Although not specifically described in this report, the Board is also concerned that the rate of these deficiencies increased during the Board's 2011 inspections. The Board emphasizes, however, that the findings described in this report should be considered against the broader background that, in many cases, the Inspections staff did not identify significant audit deficiencies in the portions of audits of internal control that were reviewed in 2010 and 2011, an encouraging fact that reflects well on the firms' ability to implement AS No. 5 appropriately when their engagement teams approach the issues properly.

The report is available at PCAOB's website.

December 10, 2012 in Other Regulatory Action | Permalink | Comments (0) | TrackBack (0)

FINRA Proposes to Allow Non-Party Associated Persons to Seek Expungement Relief

FINRA, at its December 2012 Board meeting, discussed several rulemaking items, including:

Expungement for Unnamed Persons in Arbitration Claims

The Board authorized FINRA to file a proposal with the SEC that establishes three different procedures that would permit registered persons who are identified for alleged sales practice violations in an arbitration claim, but are not named as parties in that claim (unnamed persons), to seek expungement relief. The unnamed person could seek relief under Rule 12805 by asking a party to the customer-initiated arbitration in writing to seek expungement on his or her behalf. Alternatively, the registered person could initiate In re proceedings under new Rule 13807 at the conclusion of the underlying customer-initiated arbitration case. Finally, the unnamed person could seek expungement relief at the conclusion of the customer’s case by asking the panel for an expungement based on the record compiled in the underlying case. The proposal incorporates many of the comments and suggestions received on Regulatory Notice 12-18, as well as feedback from several FINRA committees. FINRA believes that these proposals provide unnamed persons with a remedy to seek redress concerning allegations that could impact their livelihoods, yet maintains the protections of FINRA’s expungement rules to ensure the integrity of the CRD records.

 Conflicts of Interest Relating to Recruitment Compensation Practices

The Board authorized FINRA to seek comment in a Regulatory Notice on a proposed rule that would require a member firm that provides, or has agreed to provide, to a registered person enhanced compensation in connection with the transfer of employment (or association) of the registered person from another financial services firm (previous firm), to disclose the details of the enhanced compensation to any former customer of the registered person at the previous firm who is contacted about moving or moves their account to the new firm. The proposal would require such disclosure for one year following the date the registered person associates with the new firm. The proposed rule would not apply to enhanced compensation of less than $50,000 or to customers that meet the definition of an institutional account pursuant to FINRA Rule 4512(c), except any natural person or a natural person advised by a registered investment adviser.

December 10, 2012 in Other Regulatory Action, Securities Arbitration | Permalink | Comments (0) | TrackBack (0)

SEC Charges Eight Former Fund Directors with Violating Asset Pricing Responsibilities

The SEC issued an order charging eight former members of the boards of directors overseeing five Memphis, Tenn.-based mutual funds with violating their asset pricing responsibilities under the federal securities laws. The mutual funds involved were the RMK High Income Fund, RMK Multi-Sector High Income Fund, RMK Strategic Income Fund, RMK Advantage Income Fund, and Morgan Keegan Select Fund. The funds, which were invested in some securities backed by subprime mortgages, fraudulently overstated the value of their securities as the housing market was on the brink of financial crisis in 2007. The SEC and other regulators previously charged the funds’ managers with fraud, and the firms later agreed to pay $200 million to settle the charges.

Under the securities laws, fund directors are responsible for determining the fair value of fund securities for which market quotations are not readily available. According to the SEC’s order instituting administrative proceedings against the eight directors, they delegated their fair valuation responsibility to a valuation committee without providing meaningful substantive guidance on how fair valuation determinations should be made. The fund directors then made no meaningful effort to learn how fair values were being determined. They received only limited information about the factors involved with the funds’ fair value determinations, and obtained almost no information explaining why particular fair values were assigned to portfolio securities.

The SEC’s order alleges that the fund directors caused the funds’ violations of Rules 22c-1, 30a-3(a) and 38a-1 under the Investment Company Act of 1940.

December 10, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

Sunday, December 9, 2012

Torres-Spelliscy on the SEC's Regulation of Money in Politics

Safeguarding Markets from Pernicious Pay to Play: The SEC's Money in Politics Model for Regulatory Intervention, by Ciara Torres-Spelliscy, Stetson University - College of Law; Stetson University College of Law, was recently posted on SSRN.  Here is the abstract:

At first blush, the SEC’s regulation of money in politics may seem to fall outside of its jurisdiction, but this is a mistake. This view ignores three previous times when the SEC stepped in to curb pay to play: (1) in the municipal bond market in 1994; (2) in the public pension fund market in 2010; and (3) in investigating questionable payments post-Watergate from 1974 to 1977. The result of the first two interventions led to new Commission rules and the third intervention resulted in the Foreign Corrupt Practices Act (a federal statute).

When these three previous SEC interventions into the role of money in politics are examined, a principled model emerges for when the Commission’s regulatory intervention is appropriate. The principled model, hereinafter known as the “Money in Politics Model,” has the following characteristics: there must be (1) a potential for market inefficiencies; (2) a problem that is not likely self-correct through normal market forces; (3) a lack of transparency; (4) a material amount of aggregated money at stake; and (5) a high probability for corruption of the government.

The Money in Politics Model’s characteristics were present in the all three past SEC interventions. As will be explained in more detail below, in the municipal bond market and public pension funds, there was an endemic problem of pay to play between state elected officials and businesses eager to contract with them for lucrative fees. The post-Watergate investigation revealed even more profound problem of secret corporate funds used for political contributions domestically and bribes of foreign officials abroad.

So does the post-Citizens United world of corporate political spending rise to the same level as these three previous examples? Does post-Citizens United political spending fit the SEC’s Money in Politics Model and merit the SEC’s intervention? This article will argue that the Model fits and the SEC should act.

The SEC is not new to the inherent conflicts of interest between business and government, especially when elected officials have the ability to make private contractors in the financial services industry rich through commissions and fees. The risk of corruption is intrinsic in such a situation. Here corruption is best captured by the definition as “the misuse of public … office for direct or indirect personal gain.” What is new as of January 2010, thanks to Citizens United, is the potential for every publicly traded company to try to influence the government not just through traditional lobbying, but also through campaign expenditures. This new problem merits a new SEC intervention to reveal the campaign activities of public companies.

December 9, 2012 in Law Review Articles | Permalink | Comments (0) | TrackBack (0)

Squire on the Benefits of a Clearinghouse in a Financial Crisis

The Speed and Certainty Benefits of a Clearinghouse in a Financial Crisis, by Richard Squire, Fordham University School of Law, was recently posted on SSRN.  Here is the abstract:

The Article argues that the primary benefit of a clearinghouse in a financial crisis is to accelerate payouts to creditors when a trading firm fails. Through netting, clearinghouses provide immediate payouts to creditors who otherwise would have to wait for slower bankruptcy payouts. Quicker payouts reduce illiquidity and uncertainty, two sources of systemic risk. Clearinghouse netting can reduce illiquidity and uncertainty even if the clearinghouse is itself insolvent. Unlike benefits of clearinghouses purported by other scholars, faster payouts are not zero-sum: besides accelerating payouts to members, clearinghouses ease the administrative burden on the failed member’s bankruptcy trustee or receiver, permitting quicker payouts to non-clearinghouse creditors as well. By identifying faster payouts as the main systemic benefit of clearinghouses, this Article shows that there is a high degree of complementarity between the Dodd-Frank Act’s clearing mandate, which requires central clearing of swap contracts, and the statute’s “orderly liquidation authority” for large financial firms. The clearing mandate will reduce the need for the liquidation authority to be invoked, and when the authority is invoked the mandate will simplify the FDIC’s duties as receiver.

December 9, 2012 in Law Review Articles | Permalink | Comments (0) | TrackBack (0)

Green & Podgor on Corporate Internal Investigations

Unregulated Corporate Internal Investigations: Achieving Fairness for Corporate Constituents, by Bruce A. Green , Fordham University School of Law, and Ellen S. Podgor, Stetson University College of Law, was recently posted on SSRN.  Here is the abstract:

This Article focuses on the relationship between corporations and their employee constituents in the context of corporate internal investigations, an unregulated multi-million dollar business. The classic approach provided in the 1981 Supreme Court opinion, Upjohn v. United States, is contrasted with the reality of modern-day internal investigations that may exploit individuals to achieve a corporate benefit with the government. Attorney-client privilege becomes an issue as corporate constituents perceive that corporate counsel is representing their interests, when in fact these internal investigators are obtaining information for the corporation to barter with the government. Legal precedent and ethics rules provide little relief to these corporate employees. This Article suggests that courts need to move beyond the Upjohn decision and recognize this new landscape. It advocates for corporate fair dealing and provides a multi-faceted approach to achieve this aim. Ultimately this Article considers how best to level the playing field between corporations and their employees in matters related to the corporate internal investigation.

December 9, 2012 in Law Review Articles | Permalink | Comments (0) | TrackBack (0)

Friday, December 7, 2012

SEC Charges Miami Entrepreneur with Stealing Investors' Money

The SEC charged Claudio Osorio, whom it describes as a prominent Miami-based entrepreneur, with defrauding investors by grossly exaggerating the financial success of his company that purportedly produced housing materials to withstand fires and hurricanes. Instead, Osorio allegedly stole nearly half of the money raised from investors to pay the mortgage on his multi-million dollar mansion and other lavish highlife expenses.

The SEC alleges that Osorio, who is a former Ernst & Young Entrepreneur of the Year award winner, raised at least $16.8 million from investors by portraying InnoVida Holdings LLC as having millions of dollars more in cash and equity than it actually did. Osorio sometimes solicited investors one-on-one at political fundraising events. To add an air of legitimacy to his company, Osorio assembled a high-profile board of directors that included a former governor of Florida, a lobbyist, and a major real estate developer. Osorio falsely told a potential investor he had invested tens of millions of dollars of his own money as InnoVida's largest stakeholder, and he hyped a Middle Eastern sovereign wealth fund investment as a ruse to solicit additional funds from investors.

The SEC also charged InnoVida's chief financial officer Craig Toll, a certified public accountant living in Pembroke Pines, Fla., who helped Osorio create the false financial picture of InnoVida.

In a parallel action, the U.S. Attorney's Office for the Southern District of Florida today announced criminal charges against Osorio and Toll.

December 7, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

SEC Charges Florida Attorney with Issuing Fraudulent Opinions to Transfer Restricted Shares

The SEC filed charges against Guy M. Jean-Pierre, a Florida-based securities lawyer, for issuing fraudulent attorney opinion letters that resulted in more than 70 million shares of microcap stock becoming available for unrestricted trading by investors. 

An attorney opinion letter is required from a licensed and duly authorized securities lawyer in order to facilitate the transfer of restricted microcap shares on the over-the-counter markets. In April 2010, the Pink Sheets (now OTC Markets Group) banned Jean-Pierre from issuing attorney opinion letters due to “repeated missing information and inconsistencies” about the issuers and his lack of due diligence in his past letters.  According to the SEC, however, Jean-Pierre has continued writing and issuing attorney opinion letters in the name of his niece, a licensed attorney, by applying her signature without her consent. Jean-Pierre (also known as Marcelo Dominguez de Guerra) sought to evade the ban by forming a new company called Complete Legal Solutions and misrepresenting that his niece was conducting the legal work that was allegedly performed.

The SEC is seeking disgorgement of ill-gotten gains with prejudgment interest and financial penalties, a permanent injunction, and a bar from participating in the offering of any penny stock pursuant to Section 20(g) of the Securities Act.

December 7, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

Massachusetts Goes After Sales of Unregistered Oil& Gas Securities in its State

Investment News reports that Massachusetts filed fraud charges against two oil and gas operations that allegedly sold unregistered securities to Massachusetts investors.  In one case, Prodigy Oil and Gas allegedly sold at least $464,000 in unregistered securities to one investor and employed a cold-caller who had previously been found guilty of fraud.  Fraud charges against Synergy Oil and two of its executives allege the sale of $35,000 in unregistered securities to two investors.  Massachusetts Secretary William Galvin has been an outspoken critic of the crowdfunding exemption contained in the JOBS Act.  Inv News, Crowdfunding takes early hit in Massachusetts

December 7, 2012 in Other Regulatory Action, State Securities Law | Permalink | Comments (0) | TrackBack (0)

Netflix and CEO Receive Wells Notices About Facebook Postings

Netflix disclosed in an 8-K filing that the company and its CEO Reed Hastings have received Wells notices from the SEC staff, indicating that it intends to recommend to the Commission that it institute a proceeding against them for violations of Regulation FD, in connection with a July posting by Hastings on his Facebook page about Netflix that members were enjoying over a billion hours per month of Netflix.  The comment was  picked up by the press and widely reported; the company did not issue a press release or file an 8-K at the time.

Hastings outlines two principal defenses to the SEC charges.  First, a posting to over 200,000 people is public.  Second, the fact of 1 billion hours of viewing in June was not "material" information, particularly since there had been an earlier blog that the company was serving "nearly" 1 billion per month.

December 7, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

Thursday, December 6, 2012

FINRA Issues Guidance on Private Placement Rules

FINRA posted on its website Frequently Asked Questions About Sale of Private Placements under FINRA Rules 5122 and 5123.

December 6, 2012 in Film, Other Regulatory Action | Permalink | Comments (0) | TrackBack (0)

SEC Staff Releases Report on Money Market Fund Reforms

The SEC's Division of Risk, Strategy, and Financial Innovation posted on the SEC's website Responses to Questions Posed by Commissioners Aguilar, Paredes, and Gallagher(Download Money-market-funds-memo-2012[1]). The report addresses questions posed by the Commissioners in a September 17, 2012 memorandum.  The report addresses:

  • causes of investor redemptions of prime money market fund shares and purchases of Treasury money market fund shares during the 2008 financial crisis
  • the efficacy of the 2010 money market fund reforms
  • how money market funds would likely have performed during the events of September 2008 had the 2010 reforms been in place at the time.

 Commissioner Aguilar, in turn, released a Statement on Money Market Funds as to Recent Developments, in which he cited both the release of the Study and "the serious consideration by the SEC staff and FSOC of the potential migration of money fund assets to opaque, unregulated funds" as welcome developments.

December 6, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

SEC Charges Wells Fargo Banker with Insider Trading

The SEC charged John W. Femenia, an investment banker at Wells Fargo Securities, and nine others with involvement in an insider trading ring that garnered more than $11 million in illicit profits trading on confidential information about impending mergers.

The SEC alleges that Femenia misused his position at Wells Fargo to obtain material, nonpublic information about four separate merger transactions involving firm clients. According to the SEC, upon learning inside information about an impending deal, Femenia would typically call his longtime friend Shawn C. Hegedus, who worked as a registered broker. Femenia and Hegedus illegally tipped other friends who in turn tipped more friends or family members in a ring that spread across five states.  

According to the SEC’s complaint, the illegal trading occurred from July 2010 to July 2012 and involved the following transactions:

The acquisition of ATC Technology Corporation by GENCO Distribution Systems (publicly announced July 19, 2010)
The acquisition of Smurfit-Stone Container Corp. by Rock-Tenn Company (publicly announced Jan. 23, 2011)
The acquisition of K-Sea Transportation Partners by Kirby Corporation (publicly announced March 13, 2011)
The acquisition of The Shaw Group by Chicago Bridge & Iron Co. (publicly announced July 30, 2012)

The court entered a temporary restraining order freezing the assets of the defendants and relief defendants. The court order also provides for expedited discovery and prohibits the defendants and relief defendants from destroying evidence.

December 6, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)

NASAA Gears Up for Internet Fraud In Wake of JOBS Act Crowdfunding

According to the NASAA, "crowdfunding’s presence on the Internet has risen sharply in recent months in anticipation of rules to allow small businesses and entrepreneurs to raise investments online."  NASAA Sees Sharp Spike in Crowdfunding Presence on the Internet

An analysis of Internet domain names by state and Canadian securities regulators found nearly 8,800 domains with “crowdfunding” in their name as of November 30, 2012, up from less than 900 at the beginning of the year. Of these websites, about 2,000 contained content, more than 3,700 had no content and more than 3,000 appeared to be “parked” and serving as placeholders to reserve a domain name for later use or sale. Of the domains with “crowdfunding” in their name, about 6,800 have appeared since April, 2012 when the JOBS Act was signed into law.

The release goes on to say

Anticipating an increase in online fraud stemming in part from passage of the JOBS Act, NASAA created a task force on Internet fraud investigations shortly after the enactment of the JOBS Act to monitor crowdfunding and other Internet offerings. The group is currently coordinating multi-jurisdictional efforts to scan various online offering platforms for fraud, and, where authorized, will coordinate investigations into online or crowdfunded capital formation fraud.

December 6, 2012 in Books, Other Regulatory Action | Permalink | Comments (0) | TrackBack (0)

SEC & FINRA Offer Suggestions on Year-End Investment Considerations

The SEC's Office of Investor Education and Advocacy and FINRA issued an Investor Alert to provide individual investors with a few suggestions for year-end investment planning, including

  • Review your asset allocation
  • consider rebalancing
  • tax considerations
  • check out your investment professiona
  • locate your financial records.

Year-End Investment Considerations for Individual Investors

December 6, 2012 in Other Regulatory Action, SEC Action | Permalink | Comments (0) | TrackBack (0)

Wednesday, December 5, 2012

Big Lots CEO Steps Down as SEC Looks into Stock Sales

Yesterday Big Lots Inc. announced that its CEO Steven Fishman intends to retire to spend time with his family.  Today the Wall St. Journal headline is that the SEC is conducting an inquiry into Fishman's $10 million sale of Big Lots stock in advance of the company's release of bad news in March 2012.  The WSJ cited Fishman's sale in its recent article that highlighted executives' trading in their companies' stock under Rule 10b5-1 plans.  WSJ, Big Lots Chief Probed by SEC

December 5, 2012 in News Stories | Permalink | Comments (0) | TrackBack (0)

Tuesday, December 4, 2012

Rep. McHenry Charges Schapiro Delayed JOBS Implementation Because of Concern over Legacy

There has been quite a lot of heat in the last few days about whether SEC Chairman Schapiro delayed implementation of Section 201 of the JOBS Act, which requires the SEC to remove the ban on general solicitation for certain issuers, in order to preserve her pro-investor legacy.  (see WSJ, WSJ UPDATE: SEC Chief Schapiro Delayed Rule Over Legacy Concerns).  The SEC has posted on its website the letter from Rep. Patrick McHenry, Chairman of the Subcommittee on TARP, Financial Services and Bailouts of Public and Private Programs, which occasioned the firestorm.

Rep. McHenry objects to the Commission's August 29, 2012 adoption of a proposal to implement Section 201 instead of an interim final rule because "the delay in implementation of Section 201 is a significant obstacle to capital formation and economic recovery."  The letter sets forth various emails that, Rep. McHenry charges, "imply that [Schapiro] personally intervened to delay implementation of the law in an effort to appease special interest groups and out of concern for your legacy as Chairman."  Rep. McHenry charges that "one late communication from a well-placed lobbyist effectively stalled the implementation of Section 201" -- i.e., Barbara Roper, of the Consumer Federation of America, who in an email communicated "strong objections" to the draft interim final rule.

December 4, 2012 in SEC Action | Permalink | Comments (0) | TrackBack (0)