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Jul 2015

Securities Enforcement 2015 Mid-Year Review

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In the first half of 2015, the SEC’s Enforcement Division announced a number of significant enforcement achievements, including settling several important cases, obtaining admissions from settling defendants, and continuing to make substantial whistleblower awards. At the same time, the first half of 2015 has been marked by increasing controversy over the use of administrative proceedings (APs) to litigate enforcement actions. Also, public dissents by certain commissioners suggest significant policy differences within the Commission with respect to, among other things, the granting of so-called bad-actor waivers to large financial institutions that have admitted to conduct that would result in automatic disqualification from certain activities.

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