U.S. Securities and Exchange Commission (SEC) settlements are meant to serve a public good by providing clear guidance as to the rules of the road and the consequences of ignoring them.
Lack of Transparency In SEC Settlement Penalty Calculations May Frustrate Self-reporting
SEC settlements often lack explanation as to how the civil monetary penalties were calculated per the statutory framework or why such penalties were appropriate under the circumstances. This lack of transparency tends to create market confusion and may frustrate certain behavior the SEC seeks to encourage, namely self-reporting.
By
Michael J. Osnato Jr., Meaghan Kelly and Stephanie Hon
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