Securities and Exchange Commission (SEC) Chairman Jay Clayton recently announced a change in how the SEC will consider requests for waivers of certain serious collateral consequences that would otherwise result from settlement of an SEC enforcement action.
SEC's Reboot on Waiver Requests in Enforcement Settlements
SEC Chairman Jay Clayton recently announced a change in how the SEC will consider requests for waivers of certain serious collateral consequences that would otherwise result from settlement of an SEC enforcement action. These collateral consequences, often referred to as "bad actor" or "bad boy" provisions, can vary greatly and may disqualify an entity from conducting certain business or utilizing certain means to offer securities.
By
Robert J. Anello and Richard F. Albert
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