Michael J Osnato Jr

December 01, 2023 | New York Law Journal

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. Yet 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.

By Michael J. Osnato Jr., Meaghan Kelly and Stephanie Hon

10 minute read

April 01, 2022 | New York Law Journal

This article highlights two recent settled actions—'In the Matter of Andeavor' and 'In the Matter of App Annie'—both of which are generally perceived to involve expansive interpretations of the securities laws. Both of these first-of-its-kind settlements also appear to lack detailed discussion of how or why the conduct at issue gave rise to the specific charged violations of the securities laws.

By Michael J. Osnato Jr. and Meaghan A. Kelly

8 minute read