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Cady Bar the Door Insight & Commentary on SEC Enforcement Actions and Related Issues

Category Archives: Structured and New Products

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Judge Rakoff Reversed by Second Circuit on SEC-Citi case, Still Sort of Wins

Posted in SEC Litigation, Structured and New Products

You’d be forgiven if you’d forgotten at this point, but way back in Obama’s first term, the SEC once investigated and sued Citigroup for its involvement in a collateralized debt obligation deal.  As the SEC said in its complaint, Citigroup told investors that a CDO fund had been populated with assets selected by an independent… Continue Reading

Wells Notices May Not Compel Disclosure, at Least for Now

Posted in SEC Litigation, Structured and New Products

On June 21st, Judge Paul Crotty largely denied a motion to dismiss in Richman v. Goldman Sachs Group, Inc. (S.D.N.Y.), private litigation surrounding the same CDOs that were the subject of the SEC’s famous enforcement action against Goldman in 2010.  While many of the plaintiffs’ claims survived to reach discovery, the court rejected one: a… Continue Reading

SEC Files Rare Subpoena Enforcement Action against Wells Fargo

Posted in SEC Litigation, Structured and New Products

Though it hardly seems this way from the outside, the SEC’s enforcement staff is in a somewhat difficult position in its investigations.  The staff issues voluntary requests or administrative subpoenas to entities with potentially responsive documents, and then it waits.  If a company doesn’t respond quickly, or at all, what is the SEC going to… Continue Reading