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SEC as Enforcer of SPAC Mergers and Enabler of SPACs | Arnall Golden Gregory LLP

SEC as Enforcer of SPAC Mergers and Enabler of SPACs | Arnall Golden Gregory LLP
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Blog: Should the SEC change its approach to financial penalties? | Cooley LLP

On Tuesday, SEC Commissioner  Caroline Crenshaw spoke to the Council of Institutional Investors.  Her presentation, Moving Forward Together Enforcement for Everyone, concerned “the central role enforcement plays in fulfilling our mission, how investors and markets benefit, and how a decision made 15 years ago has taken us off course.” In her view, the SEC should revisit its approach to assessing financial penalties and should not be reluctant to impose appropriately tailored penalties that effectively deter misconduct, irrespective of the impact on the wrongdoer’s shareholders. Is this a sign of things to come?   Crenshaw observes that, generally, SEC Commissioners of all stripes believe in a strong enforcement program but differ on the effect of corporate penalties in achieving the SEC’s goals.  Crenshaw believes that the SEC has overemphasized “factors beyond the actual misconduct when imposing corporate penalties including whether the corporation’s shareholders

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