Securities Industry Commentator by Bill Singer Esq

JP Morgan Securities Sued for Over $10 Million in Team Dissolution FINRA Arbitration (BrokeAndBroker.com Blog)

Former Head of Corporate Communications of $21 Billion Biopharmaceutical Company Admits Insider Trading (DOJ Release)

Federal Indictment Charges CPA With Securities Fraud / More than 19 investors at or near retirement age lost over $3.6 million (DOJ Release)

Justice Department Secures Groundbreaking Settlement Agreement with Meta Platforms, Formerly Known as Facebook, to Resolve Allegations of Discriminatory Advertising / Lawsuit is the Department's First Case Challenging Algorithmic Discrimination Under the Fair Housing Act; Meta Agrees to Change its Ad Delivery System (DOJ Release)

Rip Current Rulemakings: Statement on the Regulatory Flexibility Agenda by SEC Commissioner Hester M. Peirce

SEC Charges Egan-Jones Ratings Co. and CEO with Conflict of Interest Violations (SEC Release)

SEC Obtains Final Judgment Against Former Pharmacy Chain Employee Charged with Insider Trading (SEC Release)

Collapse of stablecoin TerraUSD sparks bold 'scheme liability' suit (Reuters by Alison Frankel)

FINRA Suspends Rep for Discretionary Trading

In the Matter of Thomas Michael Hallberg, Respondent (FINRA AWC)

FINRA Suspends Rep for PST and Personal Email

In the Matter of Brian F. Donnelly, Respondent (FINRA AWC)

122 Days And Counting For FINRA's Independent Review Of Its Arbitration Selection Process (BrokeAndBroker.com Blog)

From 2018 through October 2020, Malik was the chief financial officer (CFO) of a New Jersey-based biopharmaceutical company listed on the NASDAQ Stock Exchange. On April 6, 2020, the company publicly announced for the first time that its breast cancer drug - an antibody-based drug designed to treat certain breast cancer patients who had very limited treatment options beyond chemotherapy - had proven effective in pre-market clinical trials. In October 2020, another biopharmaceutical company acquired the company for which Malik worked for approximately $21 billion.

Malik was among the first, and one of the few, employees who received the material non-public information about the breast cancer drug before the public announcement. Within minutes of obtaining that information, Malik passed it along to Wood, who lived with Malik at the time and was formerly employed by the same company. Before April 6, 2020, and within hours of receiving the insider information from Malik, Wood placed an order for approximately 7,000 shares of the company's stock, despite the fact that during the same time period the company's stock was downgraded by financial experts. After the company announced that its cancer drug had proven effective in pre-market clinical trials, its stock price increased. After selling her shares, Wood more than doubled her investment, realizing gross profits of $213,618.

[B]etween 2012 and 2019, Billings engaged in securities fraud through his company, Alpha Finance Company (ALPHA), located in Sparta, North Carolina. The indictment alleges that Billings fraudulently obtained more than $3.6 million from at least 19 victims throughout Alleghany, Wilkes and Surry Counties, by soliciting them to invest in ALPHA via "debenture notes." A debenture note is a type of debt instrument typically not backed by a collateral. As alleged in the indictment, Billings, who is a licensed North Carolina CPA, falsely promised ALPHA's victim-investors that their money would be used to make high interest consumer loans from which the investors would receive interest payments. Contrary to his promises, Billings used little, if any, of the investors' funds to make new consumer loans. Rather, Billings used some of the investors' money to make payments to other investors and to pay himself over $1 million in salary and distributions from ALPHA.

The indictment further alleges that Billings used investment statements, emails and meetings to mislead and deceive victim-investors into believing that ALPHA was a profitable company and that the victims' investments were safe. In this regard, Billings allegedly failed to disclose material information concerning ALPHA's financial and business troubles to victim-investors, including that he had sold or mortgaged most of ALPHA's assets to hard money lenders. Based on the fraudulent information provided by Billings, many of the victim-investors renewed and/or made additional investments with ALPHA, causing them to incur further financial losses.

Finally, lawsuits brought by the North Carolina Commissioner of Banks (NCCOB) and the North Carolina Attorney General's Office alleged that Billings failed to comply with North Carolina laws governing consumer finance and retail installment loans.  Billings defaulted on these lawsuits. Consequently, the NCCOB revoked ALPHA's license due to non-compliance with North Carolina's Consumer Finance Act. Courts in Alleghany and Wake Counties declared ALPHA's loan null and void, leaving the investor-victims with no assets to recoup their losses.

United States' Lawsuit

The United States' complaint challenges three key aspects of Meta's ad targeting and delivery system. Specifically, the department alleges that:

• Meta enabled and encouraged advertisers to target their housing ads by relying on race, color, religion, sex, disability, familial status and national origin to decide which Facebook users will be eligible and ineligible to receive housing ads.
• Meta created an ad targeting tool known as "Lookalike Audience" or "Special Ad Audience." The tool uses a machine-learning algorithm to find Facebook users who share similarities with groups of individuals selected by an advertiser using several options provided by Facebook. Facebook has allowed its algorithm to consider FHA-protected characteristics - including race, religion and sex - in finding Facebook users who "look like" the advertiser's source audience and thus are eligible to receive housing ads.
• Meta's ad delivery system uses machine-learning algorithms that rely in part on FHA-protected characteristics - such as race, national origin and sex - to help determine which subset of an advertiser's targeted audience will actually receive a housing ad.

The complaint alleges that Meta has used these three aspects of its advertising system to target and deliver housing-related ads to some Facebook users while excluding other users based on FHA-protected characteristics.

The department's lawsuit alleges both disparate treatment and disparate impact discrimination. The complaint alleges that Meta is liable for disparate treatment because it intentionally classifies users on the basis of FHA-protected characteristics and designs algorithms that rely on users' FHA-protected characteristics. The department further alleges that Meta is liable for disparate impact discrimination because the operation of its algorithms affects Facebook users differently on the basis of their membership in protected classes.

Settlement Agreement

These are the key features of the parties' settlement agreement:

• By Dec. 31, 2022, Meta must stop using an advertising tool for housing ads known as "Special Ad Audience" (previously called "Lookalike Audience"), which relies on an algorithm that, according to the United States, discriminates on the basis of race, sex and other FHA-protected characteristics in identifying which Facebook users will be eligible to receive an ad.
• Meta has until December 2022 to develop a new system for housing ads to address disparities for race, ethnicity and sex between advertisers' targeted audiences and the group of Facebook users to whom Facebook's personalization algorithms actually deliver the ads. If the United States concludes that this new system sufficiently addresses the discriminatory disparities that Meta's algorithms introduce, then Meta will fully implement the new system by Dec. 31, 2022.
• If the United States concludes that Meta's changes to its ad delivery system do not adequately address the discriminatory disparities, the settlement agreement will terminate and the United States will litigate its case against Meta in federal court.
• The parties will select an independent, third-party reviewer to investigate and verify on an ongoing basis whether the new system is meeting the compliance standards agreed to by the parties. Under the agreement, Meta must provide the reviewer with any information necessary to verify compliance with those standards. The court will have ultimate authority to resolve disputes over the information that Meta must disclose.
• Meta will not provide any targeting options for housing advertisers that directly describe or relate to FHA-protected characteristics. Under the agreement, Meta must notify the United States if Meta intends to add any targeting options. The court will have authority to resolve any disputes between the parties about proposed new targeting options.
• Meta must pay to the United States a civil penalty of $115,054, the maximum penalty available under the Fair Housing Act.

Chair Gensler's Regulatory Flexibility Agenda[1] for the Securities and Exchange Commission sets forth flawed goals and a flawed method for achieving them. The agenda, if enacted, risks setting off the regulatory version of a rip current-fast-moving currents flowing away from shore that can be fatal to swimmers. Just as certain wave and wind conditions can create dangerous rip currents,[2] the pace and character of the rulemakings on this agenda make for dangerous conditions in our capital markets.

I. The Agenda Devotes the Agency's Limited Resources to Rulemaking Proposals Disconnected from our Core Mission

The Agenda continues to shun issues at the core of our mission in favor of shiny objects outside our jurisdiction. We used to focus on companies' disclosure of economically material information; we now focus on disclosure of hot-button matters outside our remit.[3] We once sought to protect retail investors; we now rush to the aid of professional investors.[4] We once worked to help small and emerging companies raise the funds that are their lifeblood; we now work to increase their costs and shrink their investor base.[5] We once hoped to increase the ranks of public companies by making it less costly and more beneficial to be public; we now look for ways to force companies to go public[6] since we are making it costlier to go public and be public.[7]

The Agenda does contemplate pursuit of some important mission-focused rules, such as updates to the investment adviser custody rules,[8] data security rules for the Consolidated Audit Trail,[9] updates to the electronic recordkeeping rules for broker-dealers,[10] and rules to shift from paper to electronic filings.[11] Yet, it drops or postpones indefinitely too many others, including transfer agent rules,[12] a joint project with the Commodity Futures Trading Commission to develop uncleared swap portfolio margining rules,[13] rules on investment company securities lending arrangements,[14] and rules to reform proxy plumbing infrastructure[15] and the fund proxy system.[16] Precious regulatory bandwidth is instead devoted to reopening rules that we only recently finished, such as the resource extraction,[17] proxy voting,[18] shareholder proposals,[19] and whistleblower rules[20]-even though we have no new information that could justify revisions so soon (less than two years) after we last considered these rules. Although the Agenda includes rules that might regulate crypto protocols or platforms through an unmarked backdoor,[21] it does not appear to include any rules primarily intended to grapple with the main regulatory questions that have arisen around these assets.[22]

II. The Agenda Breaks with the Commission's Longstanding Tradition of Deliberative Rulemaking that Facilitates Broad Participation by Affected Market Participants

Compounding the substance concerns are process concerns. We have abandoned our careful and considered approach to altering regulation in favor of effecting hasty and sweeping change.

The Agenda's timetables reveal that the rush of radical rulemakings remains relentless, despite pleas from almost every type of market participant and other interested party that the Commission slow down so that the public can catch up and provide meaningful input on our outstanding proposals.[23] These rules contemplate far-reaching changes to our regulatory regime, the breadth of which is hard to glean from merely reading their titles.[24] The Agenda plans to rush to completion proposals in which commenters have identified deep flaws.[25] Implementation of these rules presumably will also be on the fast track, which suggests that market participants will have to implement multiple complex rulemakings simultaneously.

Intensifying the problem, as the Agenda reveals, more proposals are on the way. The Commission plans to propose many new rules, contemplating further extensive changes within the next five months.[26] Even rules on the Agenda that are important to our mission stand no chance of receiving comprehensive public feedback. Issuing 3-5 rule proposals per month is not consistent with affording the public time to thoughtfully consider (let alone cogently comment on) how such changes will affect investors, markets, or day-to-day business operations of market participants. I also have concerns that the volume of comment requests will give even greater weight to the views of bigger players and mute the voices of retail investors, smaller advisers, broker-dealers, mutual funds, and companies, which lack the resources necessary to give each of these proposals the attention they deserve. Even if commenters are able to provide us careful feedback on individual rules, the rulemaking volume impedes the provision of data, the preparation of in-depth analyses, and the consideration of how these rules will interact with one another.

The Commission recently extended or reopened the comment periods for some proposed rules[27]and afforded longer comment periods for two recent rulemaking proposals.[28] I commend Chair Gensler for appreciating the need for more time on these matters. I urge the Commission for all rules to build in more reasonable comment periods at the time we propose new rules. Commenters need time to read our lengthy releases, decide which of the many questions to answer, gather the information necessary to answer them, and synthesize the information into a comment letter. If commenters think that a proposal's comment period will be only thirty or sixty days, they may not invest in gathering data or performing economic analysis for submission to the comment file. Why undertake a costly study or data collection exercise that may not be ready before the comment period is up? Providing more reasonable comment periods up front would better help the public understand how to spend their time and resources providing us with feedback. I hope that the Commission will embrace both longer comment periods and reasonable implementation periods.

III. Conclusion

When the Commission attempts rapidly to write and implement myriad rules, many of which are outside our longstanding mandate, it sets up conditions that could roil the markets. We can avoid creating regulatory rip currents by recalibrating our agenda to focus on issues core to the protection of investors and operation of our markets and by slowing down the pace to ensure that we and the public can think about what we are doing.

[1] Securities and Exchange Commission (SEC), Agency Rule List (Spring 2022),Agency Rule List - Spring 2022 (reginfo.gov) [hereinafter Agenda].

[2] See Rip Current Hazards (General Information), National Weather Service, https://www.weather.gov/mhx/RipCurrentsInfo.

[3] See, e.g., Agenda, supra note 1, stating that: "The Division is considering recommending that the Commission propose rule amendments to enhance registrant disclosures about the diversity of board members and nominees"; "The Division is considering recommending that the Commission adopt rule amendments to enhance registrant disclosures regarding issuers' climate-related risks and opportunities."; "The Division is considering recommending that the Commission propose rule amendments to enhance registrant disclosures regarding human capital management."

[4] See, e.g., id. ("The Division is considering recommending that the Commission adopt rules under the Advisers Act to address lack of transparency, conflicts of interest, and certain other matters involving private fund advisers."). These retail-like rules for private fund advisers will necessitate the expenditure of Commission resources to examine and bring enforcement actions against advisers that serve highly paid institutional investors, rather than retail investors.

[5] See, e.g., id. ("The Division is considering recommending that the Commission propose amendments to Regulation D, including updates to the accredited investor definition, and Form D to improve protections for investors.").

[6] See, e.g., id. ("The Division is considering recommending that the Commission propose amendments to the 'held of record' definition for purposes of section 12(g) of the Exchange Act.").

[7] See, e.g., Proposed Rule No. 34-94546, Special Purpose Acquisition Companies, Shell Companies, and Projections (Mar. 30, 2022), https://www.sec.gov/rules/proposed/2022/33-11048.pdf [hereinafter SPAC and Shell Company Proposal]; see also Agenda, supra note 1 ("The Division is considering recommending that the Commission adopt rule amendments to better inform investors about a registrant's cybersecurity risk management, strategy and governance, and to provide timely notification of material cybersecurity incidents. The Commission proposed rules to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance, and cybersecurity incident reporting by public companies that are subject to the reporting requirements of the Exchange Act."); see also id. ("The Division is considering recommending that the Commission adopt rule amendments to enhance registrant disclosures regarding issuers' climate-related risks and opportunities.").

[8] See Agenda, supra note 1 ("The Division is considering recommending that the Commission propose amendments to existing rules and/or propose new rules under the Investment Advisers Act of 1940 to improve and modernize the regulations around the custody of funds or investments of clients by Investment Advisers.").

[9] See id. ("The Division is considering recommending that the Commission adopt amendments to the National Market System Plan Governing the Consolidated Audit Trail regarding data security.").

[10] See id. ("The Division is considering recommending that the Commission propose rule amendments that would require the electronic submission to the Commission of certain filings by broker-dealers, security-based swap entities, self-regulatory organizations and clearing agencies. Most of these reports are currently filed with the Commission in paper form.").

[11] See id. ("The Division is considering recommending that the Commission adopt amendments to rules and forms to require that the following types of filings be submitted electronically: (1) applications for orders under any section of the Investment Advisers Act of 1940, (2) confidential treatment requests for filings made under section 13(f) of the Securities Exchange Act of 1934, and (3) ADV-NR.").

[12] See id. (stating that the next action date for the Division to recommend transfer agent rule proposals is "undetermined").

[13] See id. (stating that the next action date for the Division to recommend proposed amendments in this area is "undetermined").

[14] See id. (withdrawing this item from the Agenda).

[15] See id. (stating that the next action date for the Division to make a recommendation in this area is "undetermined").

[16] See id. (withdrawing this item from the Agenda).

[17] See id. ("The Division is considering recommending that the Commission review the rules under Section 1504 of the Dodd-Frank Act to determine if additional amendments might be appropriate."). These rules were last amended in December 2020. See Final Rule No. 34-90679, Disclosure of Payments by Resource Extraction Issuers (Dec. 16, 2020), https://www.sec.gov/rules/final/2020/34-90679.pdf (previously amending the rules under Section 1504 of the Dodd-Frank Act).

[18] See Agenda, supra note 1 ("The Division is considering recommending that the Commission adopt rule amendments governing proxy voting advice."). These rules were adopted in July 2020. See Final Rule No. 34-89372, Exemptions from the Proxy Rules for Proxy Voting Advice (Jul. 22, 2020), https://www.sec.gov/rules/final/2020/34-89372.pdf (adopting the rules governing proxy voting advice).

[19] See Agenda, supra note 1 ("The Division is considering recommending that the Commission propose rule amendments regarding shareholder proposals under Rule 14a-8."). These rules were adopted in September 2020.See Final Rule No. 34-89964, Procedural Requirements and Resubmission Thresholds under Exchange Act Rule 14a-8 (Sep. 23, 2020), https://www.sec.gov/rules/final/2020/34-89964.pdf (adopting the rules regarding shareholder proposals under Rule 14a-8).

[20] See Agenda, supra note 1 ("The Office of the Whistleblower is considering recommending that the Commission adopt additional amendments to the rules governing the Whistleblower Program established by Section 922 of the Dodd-Frank Act."). These rules were adopted in September 2020. See Final Rule No. 34-89963, Whistleblower Program Rules (Sep. 23, 2020), https://www.sec.gov/rules/final/2020/34-89963.pdf (adopting the rules governing the Whistleblower Program).

[21] See, e.g., Proposed Rule No. 34-94062, Amendments to Exchange Act Rule 3b-16 Regarding the Definition of "Exchange"; Regulation ATS for ATSs That Trade U.S. Government Securities, NMS Stocks, and Other Securities; Regulation SCI for ATSs That Trade U.S. Treasury Securities and Agency Securities (Jan. 26, 2022), https://www.sec.gov/rules/proposed/2022/34-94062.pdf [hereinafter Amendments to Exchange Act Rule 3b-16]. Numerous commenters have responded to this rulemaking with questions about its application to crypto.

[22] Areas where regulatory clarity would be appreciated include: when is a crypto asset a security; how should crypto asset trading platforms and broker-dealers engage in crypto securities transactions alongside transactions in non-crypto securities and non-security crypto assets; how can regulated entities experiment with distributed ledger technology to enhance the efficiency and reliability of the execution, clearance, and settlement of securities transactions; and issues around the custody of crypto assets including the implications of Staff Accounting Bulletin No. 121. See SEC, Staff Accounting Bulletin No. 121 (Apr. 11, 2022), https://www.sec.gov/oca/staff-accounting-bulletin-121.

[23] For example, twenty-five trade associations, representing financial services firms whose businesses span the entirety of the securities markets wrote a letter to this effect. See Letter from Alternative Credit Council et al., to Gary Gensler, Chairman, SEC (April 5, 2022), https://www.sifma.org/wp-content/uploads/2022/02/SEC_Joint-Trades_Comment-Period-Letter_4-5-2022.pdf (concerning the "Importance of Appropriate Length of Comment Periods"). Also, in early April, a bipartisan group of 47 members of Congress signed a letter urging the agency to increase the comment period to 90 days, noting the importance of allowing stakeholders enough time to examine and respond to such complex proposed rules as the agency's Private Fund Adviser and Form PF proposals. See Letter from Bill Foster et al. to Gary Gensler, Chairman, SEC (April 13, 2022), https://www.investmentcouncil.org/47-bipartisan-lawmakers-urge-the-sec-to-increase-comment-periods/ (concerning "Private Fund Advisers; Documentation of Registered Investment Companies Compliance Reviews").

[24] To name a few examples: the Special Purpose Acquisition Companies rule applies to a broader set of business combinations than just de-SPAC transactions and would expand underwriter liability. See SPAC and Shell Company Proposal, supra note 7. Similarly the rule to expand the definition of "exchange," could draw in numerous communication protocol systems from both the traditional and decentralized finance worlds. See Amendments to Exchange Act Rule 3b-16, supra note 21. Also, the proposed rule outlining parameters of when large traders in government securities would have to register as broker-dealers could reach certain private funds and investment advisers. See Proposed Rule No. 34-94524, Further Definition of "As a Part of a Regular Business" in the Definition of Dealer and Government Securities Dealer (Mar. 28, 2022), https://www.sec.gov/rules/proposed/2022/34-94524.pdf.

[25] One example is the recently proposed rules governing public companies' share repurchases (or "buybacks"). See Tom Zanki, SEC's Stock Buyback Proposal Ignites Pushback, Law360 (Apr. 22, 2022), https://www.law360.com/articles/1485912/sec-s-stock-buyback-proposal-ignites-pushback. Despite widespread criticism, the Agenda notes the Commission is considering a recommendation to adopt the rule within the next few months. See the Agenda, supra note 1 (noting a timetable for action of October 2022). Other examples include our reforms to the Money Market Fund rules, changes under Section 10B of the Exchange Act to require certain disclosures in connection with security-based swap positions, and Securities Lending Disclosure rules. See Agenda, supra note 1 (targeting April 2023 for adoption).

[26] Within the next five months, the Agenda contemplates the Commission proposing new rules in the following areas:

1. digital engagement practices of investment advisers;
2. digital engagement practices of broker-dealers;
3. broker-dealer cybersecurity obligations;
4. fund fee disclosure;
5. public issuers' disclosure of human capital management information;
6. shareholder proposals under Rule 14a-8;
7. the Rule 144 safe-harbor;
8. Form D and the accredited investor definition;
9. the definition of "held of record," which affects the number of shareholders a private issuer can have before it must publicly register its securities;
10. open-end fund liquidity and dilution management;
11. investment adviser custody;
12. third-party services providers hired by investment advisers;
13. electronic submission of forms by broker-dealers;
14. conflicts of interest in certain securitization transactions, under Section 621 of the Dodd-Frank Act;
15. equity market structure;
16. clearing agency conflicts of interest; and
17. clearing requirements for trades in government securities.

[27] See Proposed Rule No. 34-94868, Reopening of Comment Periods for "Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews" and "Amendments Regarding the Definition of 'Exchange' and Alternative Trading Systems (ATSs) That Trade U.S. Treasury and Agency Securities, National Market System (NMS) Stocks, and Other Securities" (May 9, 2022), https://www.sec.gov/rules/proposed/2022/34-94868.pdf?utm_medium=email&utm_source=govdelivery; see also Proposed Rule No. 34-94867, The Enhancement and Standardization of Climate-Related Disclosures for Investors (May 9, 2022), https://www.sec.gov/rules/proposed/2022/33-11061.pdf?utm_medium=email&utm_source=govdelivery.

[28] Commenters will have 60 days from publication in the Federal Register to comment on the recently proposed fund names rule and investment adviser/investment company environmental, social, governance rule. See Proposed Rule No. 34-94981, Investment Company Names (May 25, 2022), https://www.sec.gov/rules/proposed/2022/33-11067.pdf; Proposed Rule No. 34-94985, Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices (May 25, 2022), https://www.sec.gov/rules/proposed/2022/33-11068.pdf.

[I]n 2019, Egan, who at the time headed Egan-Jones's ratings group, became involved in business and marketing activities concerning a client and was influenced by sales and marketing considerations while participating in determining a credit rating for that client, which created a prohibited conflict of interest. The order finds that by issuing and maintaining a rating for the client under those circumstances, Egan-Jones violated the SEC's NRSRO conflict of interest rules and, further, that Egan caused the company's violations. 

The SEC's order also finds that, in 2018, Egan-Jones violated another conflict of interest provision by continuing to issue and maintain ratings for another client even though that client had contributed ten percent or more of the company's net revenues during the prior fiscal year. Finally, the order finds that Egan-Jones failed to establish, maintain, and enforce policies and procedures reasonably designed to manage such conflicts of interest. 

On September 17, 2020, the Commission filed a complaint alleging that Sheinfeld sold nearly $1 million in Rite Aid securities in advance of news that caused the price of Rite Aid securities to drop when it became public. The complaint alleges that, after learning confidentially through his employment that the anticipated merger between Rite Aid and Walgreens would not close by an upcoming deadline, Sheinfeld liquidated all of his exercisable Rite Aid employee stock options. The complaint further alleges that Sheinfeld then accessed the accounts of his sister-in-law and adult daughter and sold all of their Rite Aid stock as well.

The key to investors' federal securities law claims against the venture capital firms is the U.S. Supreme Court's 2019 ruling in Lorenzo v. Securities and Exchange Commission. In that case, as I've reported, the Supreme Court held that investment banker Francis Lorenzo participated in a fraudulent securities scheme when he knowingly emailed false information about a client's debt offering to potential investors. The Lorenzo ruling launched a bevy of law firm client alerts about the expansion of "scheme liability" under the Securities and Exchange Act. And although shareholder lawyers told me at the time that the ruling wouldn't have a big impact on private securities fraud cases, Lorenzo has occasionally popped up in investor class actions.

• Securities Industry Commentator
• Bill Singer