The one unusual thing about the standard disclaimer is that it stayed the same for as long as I can remember. In the almost three decades that I have been practicing, SEC speakers have been saying pretty much the same disclaimer: “The views I express today are my own and do not necessarily reflect the views of the Commission, the Commissioners or the Staff.” Even when I was engaged in the rote recitation of this disclaimer, it always struck me as odd that, as a representative of the SEC at the program, I was saying that I only expressed my own views, even though obviously the views I discussed on the panel were very much aligned with SEC policy at the time. Perhaps the disclaimer made more sense for the Commissioners, who in their speeches often express political or ideological views that are not necessarily aligned with the views of the Chairman or the other Commissioners. In any event, the disclaimer was what it was, and I did not dare to alter it out of fear of suffering the unknown consequences.
‘Enforcement 40’ for 2020
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