Michael J Osnato Jr Meaghan Kelly
December 01, 2023 | New York Law Journal
The Importance of the 'How' and the 'Why' in SEC Settlement Penalty CalculationsSEC 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
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