Steve Cutler, Mike Osnato and Kelsey Vickery Author Article on Wells Process
11.21.19
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Steve Cutler, Mike Osnato and Kelsey Vickery authored an article titled, “SEC Wells Submissions: A New Caution Required?” which was published by NYU School of Law's Compliance & Enforcement Blog. The article discusses the Securities and Exchange Commission’s (SEC) recent enforcement action in SEC v. Bolton Securities Corp, and its possible implications for the Wells process, noting that the SEC’s particular use and critique of Bolton’s Wells submission may be viewed as being at odds with the purpose of the Wells process.
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