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‘Enforcement 40’ for 2020
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Join the Securities Litigation and Enforcement Group on LinkedIn2nd Circuit Is Urged to Find SEC ‘Tolling’ Agreements Unenforceable | New York Law Journal
The novel argument, which takes aim at the validity of so-called tolling agreements allowing the SEC to extend the statutory five-year window for filing an enforcement action, has never before been offered in court, and very little has been written on the subject. That is, outside of an article by a former SEC lawyer, who says […]
What If All Those SEC Tolling Agreements Were Unenforceable? | LinkedIn
Investigative subjects – particularly corporate and other business entities – usually accede to SEC demands for tolling agreements. They fear if they don’t agree the SEC staff will impose unreasonably short time deadlines for responding to subpoenas and other investigative demands. They also fear the SEC staff will rush to judgment and they might not be allowed […]