It strikes me that two civil regulators are facing dire attacks on aspects of their enforcement programs – both in different U.S. Courts of Appeals – at the same time. Both of these attacks arise out of generalized statutes that only sort of address the problems the regulators seek to remedy. To some degree, how these matters are resolved will determine whether these enforcement portfolios are reinvigorated or whither on the vine. In both cases a Congressional fix could be in order.
‘Enforcement 40’ for 2020
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