“Yeah we know you’re going to assert lack of regulatory clarity, but we factually do have extremely developed law and guidance regarding the functioning of this sort of market participant in a compliant fashion. Your problem is that you prefer not to follow those laws.”
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“You will probably assert that you do not have copies of what your underwriters told investors over DM because they do not have document retention practices equivalent to e.g. Goldman Sachs. The SEC does not perceive this as being *our* problem.”
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(If it is not obvious, these are not quotes from that document, these are vocalizations of the thought process of the SEC as interpreted by yours truly.)
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End of conversation
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It's almost as if the smart chaps think they've thought up a smart end run around regs that control billions on Wall St. like those guys wouldn't be incentivised to find them themselves.
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