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Should There Be “Bad Actor” Risk Factor?

I’ve devoted several recent posts to the Securities and Exchange Commission’s new “bad actor” rule because it is awash with a sea of troubles for issuers, both private and publicly traded.    The rule prevents issuers from relying on Rule 506 if they are or have been subject to any of a long list of…

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Some Pearls From Commissioners Past

Today’s post is dedicated to some observations on securities regulation from a few of my predecessors. H.L. Carnahan, California’s first Commissioner and later Lieutenant Governor, had this to say in 1916: The essence of the Blue Sky Laws is the spirit of fair dealing. Commissioner E.C. Bellows took an aggressive posture in 1918: These are…

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