With the end of the government fiscal year looming, the key question becomes the number and types of cases filed over the year. For the staff it is typically a rush to the finish to file every case available.

This year the focus may be different, however. Significant issues such as payment for order flow, crypto, and the adoption of new environmental disclosure standards are key. While there has been a significant amount of discussion regarding these and other topics such as those mentioned in Chair Gensler’s recent Congressional testimony, little is actually known about the positions the agency may adopt. That of course creates uncertainty. It may well be some time before there is a resolution of that uncertainty.

Be careful, be safe this week


Whistleblower: The Commission awarded about $36 million to a whistleblower who contributed to the success of an enforcement action, according to a September 24, 2021 release.

SEC Enforcement – Filed and Settled Actions

Last week the Commission filed 15 civil injunctive actions and 3 administrative proceedings, exclusive of tag-along and other similar proceedings.

Fraudulent securitization: SEC v. Collins, Civil Action No. 21-cv-5040 (N.D. Ill. Filed September 23, 2021) is an action which names as defendants James Collins and Robert Dimeo. Defendant Collins worked for Honor Finance LLC, a subprime auto loans firm. Over a period of about two years defendants defrauded investors in the Honor Automobile Trust Securitization…

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