This article, which first appeared in the Winter 2006 issue of The Investment Adviser’s Counsel, was authored by Debra M. Patalkis, partner in the firm’s Securities and Corporate Governance Litigation Practice Group, and Diana E. McCarthy, partner in the Firm’s Investment Management Group.  The article examines the Securities and Exchange Commission’s written statement issued on January 4, 2006 providing further guidance on its policy for imposing civil penalties against a corporation for securities law violations. 

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Source: The Investment Adviser's Counsel
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