In the BofA case, Judge Rakoff expressed his distaste for standard language in the SEC's settlement agreements stating that the defendant "does not admit nor deny" the SEC's allegations. He also took issue with the fact that the SEC failed to allege any specific facts against BofA.
COMPLIANCE WEEK ComplianCe Week T H E L E A D I N G I N F O R M AT I O N S E R V I C E O N C O R P O R AT E G O V E R N A N C E , R I S K , A N D C O M P L I A N C E
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"Judge Battles SEC Settlement Procedures"Please download to view full document