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 …
Tag: SARS
This Week In Securities Litigation (Week of August 17, 2020)
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 …
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