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12/4/17 - Conway Dodge on How the SEC Levies Fines

Promontory Managing Director Conway Dodge was quoted in an article in The Banker providing insight into how the Securities and Exchange Commission levies fines.

“One of the challenges is how you define an act or omission that violates or causes a violation of the securities laws, which can really impact the penalty amount,” Dodge said. “A course of conduct, for instance, may be viewed as a single act or multiple acts.”

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