SEC’s School District Enforcement Action
This issue of the Hawkins Advisory analyzes the SEC enforcement actions of July 29 relating to an Indiana school district and related violations of Rule 10-5 and Rule 15c2-12.
On July 29, 2013, the Securities and Exchange Commission (the “SEC”), in an administrative proceeding,1 accepted a settlement offer made by City Securities Corporation (the “Underwriter”) and imposed a cease‐and‐desist order. The SEC found that the Underwriter committed numerous violations of the federal securities laws. Concurrently, the SEC in administrative proceedings imposed cease‐and‐desist orders on (i) the supervisor (the “Supervisor”) of the Underwriter’s public finance department and (ii) the issuer (and obligated person),2 West Clark Community Schools, Indiana (the “School District”), whose misleading disclosures were the basis for the enforcement actions (“Order” or “Orders,” as the context indicates3).
Also of Interest
- Brian Garzione co-authored NABL’s SEC Comment Letter on Climate Change Disclosures
As the Chair of NABL’s Securities Law and Disclosure Committee, Brian was one of the principal authors of NABL’s comment letter relating to the SEC’s public statement and request for public input on climate change disclosures.
- Brian Garzione co-authors the Supplement to NABL’s Crafting Disclosure Policies
Brian was a key participant in preparing a supplement to NABL’s Crafting Disclosure Policies.
- Brian Garzione named Chair of NABL’s Securities Law and Disclosure Committee
In the fall of 2020, Brian Garzione was named Chair of NABL’s Securities Law and Disclosure Committee (SLDC).
- SEC Exemptive Order re Municipal Advisors
This Hawkins Advisory describes the SEC’s exemptive order of June 16, 2020, which provides a temporary exemption from registration as a broker for registered municipal advisors, subject to satisfaction of certain conditions.