I start out in the brave new world of blogging on a subject I know a little about. Over the years I have tried more than 50 SEC administrative proceedings for the SEC's enforcement division. My hope is that securities practitioners will find this effort to comment on SEC administrative practice useful, informative, and perhaps occasionally entertaining.
My focus will be commentary on SEC appellate decisions and any Court of Appeals decisions concerning those SEC efforts.
I start with a modest suggestion for the SEC (one I made more than a few times when I worked there).
Major pleadings by both SEC counsel and respondents' counsel such as pretrial briefs, post trial proposed findings of fact, post trial briefs and appellate briefs should be posted on the SEC website. These are public documents yet they are not easily available for the public and practitioners. They should be.
