Important Changes Are in Store for the SEC and Other Federal Agencies
Last week, the Supreme Court handed down two opinions that have the potential to limit the authority of the Securities and Exchange Commission in fundamental ways and to curtail, or at least redirect, its ability to discipline individuals and entities who violate the securities laws. Both address what some call the “administrative state.” Unsurprisingly, the court’s current conservative majority voted unanimously to reduce the powers of federal agencies.
The Demise of the Chevron Doctrine
In the more important of the two cases, the court overruled its 1984 decision in Chevron v. Natural Resources Defense Council. Chevron was an unexciting case at first glance, testing the application of the Clean Air Act Amendments of 1977. The Environmental Protection Agency’s regulations were promulgated on October 14, 1981. They involved, in part, “a plantwide definition of the term stationary source.” Justice John Paul Stevens, who wrote the eventual opinion, explained:
The question presented by these cases is whether EPA’s decision to allow States to treat all of the pollution-emitting devices within the same industrial grouping as though they were encased within a single “bubble” is based on a reasonable construction of the statutory term “stationary source.”
The case had come to the Supreme Court from the D.C. Circuit Court of Appeals. That court’s opinion was written by Ruth Bader Ginsburg. After a lengthy examination of the meaning of the word “source,” she concluded that:
[t]his court’s prior adjudications in Alabama Power and ASARCO preclude us from sanctioning EPA’s employment of the bubble concept in the Clean Air Act’s nonattainment program. We therefore grant the petition for review and vacate EPA’s October 14, 1981, regulations.
It was up to the Supreme Court to decide who was right. There, the small majority—Thurgood Marshall, William Rehnquist, and Sandra Day O’Connor “took no part in the decision”—found for the EPA and reversed the appeals court’s decision. When the appellate case was heard, the EPA’s administrator was Anne M. Gorsuch, mother of current Supreme Court justice Neil Gorsuch and a fierce advocate for deregulation. As a Reagan appointee, she considered herself a “New Federalist” who sought to delegate the agency’s work to the states.
Although, in 1984, the resolution of Chevron was seen as a victory for conservatives, over the succeeding decades, the “Chevron doctrine” and “Chevron deference” have been used to uphold the authority and powers of federal agencies. Going beyond the question of how “source” should be defined, Stevens notes:
Judges are not experts in the field, and are not part of either political branch of the Government. Courts must, in some cases, reconcile competing political interests, but not on the basis of the judges’ personal policy preferences. In contrast, an agency to which Congress has delegated policymaking responsibilities may, within the limits of that delegation, properly rely upon the incumbent administration’s views of wise policy to inform its judgments. While agencies are not directly accountable to the people, the Chief Executive is, and it is entirely appropriate for this political branch of the Government to make such policy choices — resolving the competing interests which Congress itself either inadvertently did not resolve, or intentionally left to be resolved by the agency charged with the administration of the statute in light of everyday realities.
When a challenge to an agency construction of a statutory provision, fairly conceptualized, really centers on the wisdom of the agency’s policy, rather than whether it is a reasonable choice within a gap left open by Congress, the challenge must fail. In such a case, federal judges — who have no constituency — have a duty to respect legitimate policy choices made by those who do. The responsibilities for assessing the wisdom of such policy choices and resolving the struggle between competing views of the public interest are not judicial ones: “Our Constitution vests such responsibilities in the political branches.”
For 40 years, Chevron was not seriously challenged. As the new century dawned, it was considered settled law. The precedent it set was accepted: justices were not subject matter experts in the fields in which federal agency employees worked, and the courts should defer to those employees’ expertise. Most of them are dedicated civil servants interested in what their agencies do; they are not, and do not wish to be, political actors.
But in 2022, the regard in which Chevron had long been held came into question. The vehicles for the case’s reversal were two actions involving marine fisheries in U.S. waters. The first was Loper Bright Enterprises v. Raimondo; the second was Relentless, Inc. et al. v. Department of Commerce, et. al. Since 1976, the National Marine Fisheries Service (NMFSA), which is part of the Commerce Department, has been empowered to require that fishing vessels carry federal monitors on board, in compliance with the provisions of the Magnuson-Stevens Fishery Conservation and Management Act (MSA). The purpose of the monitors was to prevent overfishing. Relentless was a similar suit brought by the owners of two fishing vessels and Seafreeze Fleet LLC.
The monitoring provisions of the MSA did not originally require that Atlantic herring fisheries pay the costs of federal monitoring. Administering the monitoring program was left to the New England Council, which develops management plans for fisheries, including herring fisheries. The NMFS’s budget suffered cuts, and in 2013, the NEC thought it had found a way to reduce costs while creating a robust monitoring program for the herring fisheries. Putting the plan into action took years, but in 2020, the NEC was ready. It shifted some of the costs of monitoring from the government to the vessel owners, which caused a considerable reduction in the fisheries’ profits. (For the sake of clarity, the monitors were individuals; the fisheries were expected to pay part of their salaries.)
The Loper Bright and Relentless suits were filed separately in federal district court. Both lost. The Loper Bright took its claims to the D.C. Circuit Court of Appeals; the Relentless plaintiffs went to the First Circuit. Their arguments were once again rejected. The courts’ decisions were guided by the principles set forth in Chevron. Even though the MSA did not explicitly require Atlantic herring fisheries to pay monitoring costs, the Chevron doctrine was developed to deal with Congress’s sometimes ambiguous or incomplete legislation.
In November 2022, Loper Bright petitioned the Supreme Court for a writ of certiorari. The Latin word “certiorari” means “to be more fully informed.” In modern law, a writ of certiorari orders a lower court to deliver its record in a case so that the higher court can review it. These petitions are not necessarily granted. Each year, the Supreme Court receives more than 7,000 petitions for review. It accepts only 100-150 of them. The cases it chooses are seen to be of national significance, may be of precedential value, or will resolve a circuit split. Four of the nine justices must vote to accept a case.
Loper Bright’s writ of certiorari contained two questions for the court:
- Whether, under a proper application of Chevron, the MSA implicitly grants NMFS the power to force domestic vessels to pay the salaries of the monitors they must carry.
- Whether the Court should overrule Chevron or at least clarify that statutory silence concerning controversial powers expressly but narrowly granted elsewhere in the statute does not constitute an ambiguity requiring deference to the agency.
The court granted the petition on May 1, 2023; in October, a similar petition by Relentless was granted, consolidating the two cases. The first question posed by Relentless was nearly identical to Loper Bright’s second: whether Chevron should be overruled. The court limited its review to the second question. The case was of great interest in the business community and among consumer groups. No fewer than 45 amicus briefs were filed in support of Loper Bright.
Oral arguments were heard on January 24, 2024. On June 28, 2024, the court struck down Chevron 6-3. The vote split along partisan lines.
Chief Justice John Roberts wrote the majority opinion. He concluded, “The Administrative Procedure Act requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority, and courts may not defer to an agency interpretation of the law simply because a statute is ambiguous; Chevron is overruled.”
He further explained that Article III of the Constitution puts the federal judiciary in charge of adjudicating disputes with consequences for the parties involved. More specifically, the Founding Fathers believed that the “final ‘interpretation of the laws’ would be ‘the proper and peculiar province of the courts.’” In his seminal decision in Marbury v. Madison, Chief Justice John Marshall similarly wrote that “it is emphatically the province and duty of the judicial department to say what the law is.” For Roberts, the question raised by Loper Bright and Relentless is as simple as that.
Offering some background, he explains that the number and powers of the administrative agencies expanded during the Roosevelt era, but even then, “… the Court often treated agency determinations of fact as binding on the courts, provided that there was ‘evidence to support the findings’… But the Court did not extend similar deference to agency resolutions of questions of law.” While the informed judgment (in the non-legal sense of the word) of the executive branch could carry “great weight,” that weight would, in a particular case, “depend upon the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it power to persuade, if lacking power to control.”
But, in the end, only the judiciary may interpret statutes. Roberts then turned to the Administrative Procedure Act (APA), which was enacted in 1946. It “governs the process by which federal agencies develop and issue regulations. It includes requirements for publishing notices of proposed and final rulemaking in the Federal Register and provides opportunities for the public to comment on notices of proposed rulemaking. The APA requires most rules to have a 30-day delayed effective date.” The act was created in reaction to concerns about the growing power of federal agencies. For Roberts:
The APA thus codifies for agency cases the unremarkable, yet elemental proposition reflected by judicial practice dating back to Marbury: that courts decide legal questions by applying their own judgment. It specifies that courts, not agencies, will decide “all relevant questions of law” arising on review of agency action, §706 (emphasis added)—even those involving ambiguous laws—and set aside any such action inconsistent with the law as they interpret it. And it prescribes no deferential standard for courts to employ in answering those legal questions.
Roberts does not address the fact that the APA provides for formal adjudication of some kinds of issues and that those proceedings may be used by “certain agencies seeking to impose civil money penalties as part of a regulatory enforcement program.” It was the APA that created the Administrative Law Judges (ALJs), which have been the subject of so much controversy in recent years.
It was Chevron, decided in 1984, that created what was an entirely new concept. When Congress had not sufficiently explained a statute—“had not directly addressed the precise question at issue”—a court could not simply impose its own interpretation. Instead, had to “set aside the traditional interpretive tools and defer to the agency if it had offered ‘a permissible construction of the statute,'” even if the agency’s interpretation was not the one the court would have arrived at on its own.
Chevron, as we’ve seen, had to do with the interpretation of amendments to the Clean Air Act. Congress had not specifically addressed the question at issue in the amendments themselves. The EPA’s interpretation, featured in the case, was a permissible reading of the Act, and so that interpretation controlled. The resolution of the case was not immediately of great interest, but over the following years, it became precedential. As Roberts says, “The Court decided that Chevron rested on “a presumption that Congress, when it left ambiguity in a statute meant for implementation by an agency, understood that the ambiguity would be resolved, first and foremost, by the agency, and desired the agency (rather than the courts) to possess whatever degree of discretion the ambiguity allows.”
Roberts and the majority believe that Chevron cannot be reconciled with the APA “by assuming that statutory ambiguities are implicit delegations to agencies.” The dissenting justices disagree. Roberts brushes away suggestions that judges are incapable of coming to grips with complex technical matters, pointing out that courts regularly deal with such things in cases not involving federal agencies. However, the agencies will not and should not be ignored. Though their interpretations “cannot bind a court,” they may be useful “to the extent it rests on factual premises within [the agency’s] expertise.” Chevron deference just doesn’t matter because judges can do it all.
Finally, Roberts turns to an issue that’s been much on the minds of Supreme Court observers in the past few years: “The only question left is whether stare decisis, the doctrine governing judicial adherence to precedent, requires us to persist in the Chevron project. It does not.” It doesn’t matter, he claims, because Chevron has “proved” to be “fundamentally flawed” and has been from the start. It, in fact, has, according to Roberts, “undermined the very “rule of law” values that stare decisis exists to secure. However, the holdings in other cases that rely on Chevron will still be valid, “despite our change in interpretive methodology.”
In his concurrence, Neil Gorsuch gives some context to the question of stare decisis:
During the tenures of Chief Justices Warren and Burger, it seems this Court overruled an average of around three cases per Term, including roughly 50 statutory precedents between the 1960s and 1980s alone… Many of these decisions came in settings no less consequential than today’s. In recent years, we have not approached the pace set by our predecessors, overruling an average of just one or two prior decisions each Term.
It would, he adds, “be wrong to read judicial opinions like statutes.” Moreover, “If stare decisis counsels respect for the thinking of those who have come before, it also counsels against doing an “injustice to [their] memory” by overreliance on their every word.” Nothing to see here, folks!
Elena Kagan, Sonia Sotomayor, and Katangi Brown Jackson dissented. Kagan wrote their opinion. She got to her point quickly:
For 40 years, Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837 (1984), has served as a cornerstone of administrative law, allocating responsibility for statutory construction between courts and agencies. Under Chevron, a court uses all its normal interpretive tools to determine whether Congress has spoken to an issue. If the court finds Congress has done so, that is the end of the matter; the agency’s views make no difference. But if the court finds, at the end of its interpretive work, that Congress has left an ambiguity or gap, then a choice must be made. Who should give content to a statute when Congress’s instructions have run out? Should it be a court? Or should it be the agency Congress has charged with administering the statute? The answer Chevron gives is that it should usually be the agency, within the bounds of reasonableness.
The thrust of her argument is that Congress cannot write laws that speak to every aspect of necessary regulatory statutes. At times, ambiguities will exist. That problem was dealt with by the principle of Chevron deference. She feels that in recent years, the Supreme Court has inserted itself and the views of its conservative majority where neither is needed, imposing its own opinions in matters like workplace health and climate change. Still, those were only a few cases. But by overruling Chevron, “the majority turns itself into the country’s administrative czar.” Roberts and his fellows insist that a radical move is required by the provisions of the APA. Kagan believes the Act demands no such thing. The overturn of Chevron is about one thing only: Courts must have more say over regulation—over the provision of health care, the protection of the environment, the safety of consumer products, the efficacy of transportation systems, and so on. A great many businesses have long sought to dispense with regulations they find expensive and inconvenient. They support replacing administrative expertise with judicial action.
The kinds of cases Chevron dealt with raised the kind of technical questions judges are unlikely to be able to answer easily. For example, Kagan asks, “When does an amino acid polymer qualify as a “protein”?” She suggests that few judges could answer with authority, while the query is likely to be easy for the scientists who work for the FDA. The courts can police agencies “to ensure that [they] act within the zone of reasonable options. But the Court does not insert itself into an agency’s expertise-driven, policy-laden functions.”
Contrary to Roberts, and especially to Gorsuch, she believes that abandoning Chevron “subverts every known principle of stare decisis.” Both stare decisis and Chevron “tell judges that they do not know everything, and would do well to attend to the views of others. So today, the majority rejects what judicial humility counsels not just once but twice over.” Kagan also believes Chevron has a “powerful constraining effect on partisanship in judicial decisionmaking.”
She closes by saying that Chevron conferred primary authorities over regulatory matters to agencies, not courts, because judges are not “experts in the field.” The truth, she says, is that the majority believes Chevron “gave agencies too much power, and courts not enough.”
Ironically, only the day before the Chevron decision was handed down, Neil Gorsuch obliged Kagan by illustrating the point she made about expertise. In the majority opinion for Ohio et. al. v. Environmental Protection Agency et. al., he referred five times to “nitrous oxide,” which is better known as “laughing gas,” the dentist’s friend. He intended to refer to “nitrogen oxide,” an air pollutant. Journalists, cable television hosts, and social media posters pounced on his mistake; the opinion was corrected a few hours later. However, the error showed that he was clearly not a subject matter expert.
How Will the End of the Chevron Doctrine Affect the SEC?
It’s too early to know precisely how the overturning of Chevron will affect the SEC. It could make a difference for several of its divisions. The agency’s ambitious rulemaking program could be forced to duke it out with critics in court and could emerge with weakened defenses against litigation. Its Climate Disclosure Rule, adopted on March 6, 2024, may be in peril. It has many critics, some of them among its own Commissioners. Hester Peirce, a Republican nominee to the Commission, has had plenty to say about what she believes is not a question with which the SEC should be involved, and she capped it with a statement issued on the day the rule was adopted. Called “Green Regs and Spam: Statement on the Enhancement and Standardization of Climate-Related Disclosures for Investors,” in it she explains why she did not vote for its adoption.
Rarely enthusiastic about enhanced disclosure regimes, Peirce found the agency’s former requirements adequate, noting that information about climate risks already appeared in the filings of 36 percent of SEC registrants. Arguing that the new rule will overwhelm, not help, investors, she adds:
The rule mandates specific granular disclosures. These include, to list a few, the process of how a company’s board oversees and is informed of climate risk, how a company’s management assesses and manages material climate risk, which management positions manage climate risk and the associated expertise, the geographic location of physical climate risk, and how climate risks affect items like a company’s “[p]roducts or services,” “suppliers,” climate mitigation activities, and “expenditures for research and development.”
Investors who believe these mandatory disclosures are too extensive and too expensive may protest. Without Chevron, the SEC can no longer expect a court simply to accept its expertise in the matter.
On August 23, 2023, the Commission adopted a rule enhancing the regulation of private fund advisers. While it contains important protections for investors, it has been challenged by private fund advisers who feel the new rules are too complicated, too expensive, and too intrusive. The National Association of Private Fund Managers; the Alternative Investment Management Association, Limited; the American Investment Council; the Loan Syndication and Trading Association; the Managed Funds Association; and the National Venture Association brought suit against the SEC, and took their case to the Fifth Circuit. On June 5, 2024, the appellate court vacated the SEC’s rule. While the agency could request an en banc rehearing or rewrite the rule, the decision in Chevron is likely to make this particular effort to protect investors more difficult.
It’s worth noting that the SEC has, for the better part of a decade, been dealing with a number of lawsuits and challenging decisions made in litigation handled by the agency’s administrative law judges. The ALJs were created by the APA. They have the authority to adjudicate enforcement actions and to impose monetary penalties on wrongdoers. The Commission can also bring civil lawsuits in federal district court, but that is more expensive and less expeditious. In the mid-2010s, the agency began relying more and more on its ALJs, sending an increasing number of cases that would once have been heard in district court to them. Defendants complained, and so did at least one judge.
That judge was Jed S. Rakoff, who sits on the federal bench in the Southern District of New York. He deals with a good deal of litigation brought by the SEC. In November 2014, he delivered an address at the P.L.I. Securities Regulation Institute. Rakoff began by explaining that while he’s generally a fan of the SEC, describing it as “one of the jewels of the federal regulatory regime,” he took issue with its “apparent new policy of bringing a greater percentage of its significant enforcement actions as administrative proceedings.” In 2013, Andrew Ceresney, then Director of the Division of Enforcement, announced the agency’s intention of bringing more cases administratively, rather than in federal court.
Rakoff explained in his speech that thanks to the Dodd-Frank Act, which was signed into law in 2010, the SEC was finally granted the power to “impose substantial monetary penalties against any person or entity whatsoever if that person or entity has violated the federal securities laws, even if the violation was unintentional.” That meant it could obtain nearly identical results from an administrative proceeding as it could from going to court. But, an administrative proceeding is in many ways unfavorable to the respondent. Rakoff explained:
To be sure, an S.E.C. enforcement action brought internally is in some superficial respects more “effective and efficient” and more “streamlined” than a similar action brought in federal court, for the simple reason that S.E.C. administrative proceedings involve much more limited discovery than federal actions, with no provision whatsoever for either depositions or interrogatories. Similarly, at the hearing itself, the Federal Rules of Evidence do not apply and the S.E.C. is free to introduce hearsay. Further still, there is no jury, and the matter is decided by an administrative law judge appointed and paid by the S.E.C. It is hardly surprising in these circumstances that the S.E.C. won 100% of its internal administrative hearings in the fiscal year ending September 30, 2014, whereas it won only 61% of its trials in federal court during the same period.
Many respondents felt the deck was stacked against them, and some sued for redress. One of the most important of these cases was Lucia et. al. v. Securities and Exchange Commission. Raymond Lucia was charged with violating the securities laws, and appeared at a hearing before ALJ Cameron Elliot. He was found liable and fined. Unhappy about his treatment, he first asked for a review of his case by the SEC and then took the matter to the DC Circuit Court of Appeals.
He argued that the administrative proceeding had been invalid because Judge Elliot had been appointed unconstitutionally. As he explained in his appeal to the Supreme Court, “SEC ALJs are “Officers of the United States” and thus subject to the Appointments Clause. Under that Clause, only the President, “Courts of Law,” or “Heads of Departments” can appoint such “Officers.” But none of those actors had made Judge Elliot an ALJ.” The SEC and the DC Circuit held that the ALJs are not officers of the United States but mere employees. The Supreme Court ruled on June 21, 2018, that ALJs were indeed officers and had been unconstitutionally appointed. The majority opinion, written by Elena Kagan, was subscribed to by seven justices; Sonia Sotomayor and Ruth Bader Ginsburg dissented.
In the end, the SEC scrambled to reappoint its ALJs correctly and distributed all the cases they’d heard in recent years to them for reexamination. The objections did not end there. The case of another respondent, George Jarkesy, goes back much further than Lucia. In 2007 and 2009, Jarkesy had formed two small hedge funds that invested in bridge loans to startups, equity investments in penny stock companies, and life settlement policies. His firm, Patriot28 LLC, was an adviser to the funds. In March 2013, making use of Dodd-Frank’s new provisions, the SEC brought an administrative proceeding against Jarkesy. In 2014, Jarkesy and Patriot28 filed an action in federal court to stay the SEC’s proceeding, arguing that it violated their Seventh Amendment right to trial by jury. The court ruled that the respondent must plead his constitutional objections before the ALJ is assigned to his case and before he can turn to federal district court. In 2020, Jarkesy and Patriot28 were found liable. The Commission imposed $300,000 in civil penalties and $685,000 in disgorgement. Jarkesy was also barred from engaging in investment-related activities.
He appealed to the Fifth Circuit and then filed a petition for a writ of certiorari with the Supreme Court. The court granted cert. The question presented was “whether the Seventh Amendment permits the SEC to compel respondents to defend themselves before the agency rather than before a jury in federal court.” The case was decided on June 27, 2024, in what has become a familiar 6-3 decision. Chief Justice Roberts’s majority opinion states further that the court must also consider “whether the ‘public rights’ exception to Article III jurisdiction applies. This exception has been held to permit Congress to assign certain matters to agencies for adjudication even though such proceedings would not afford the right to a jury trial.”
Roberts and the majority quickly decided that the exception did not apply. The action did, however, implicate the Seventh Amendment because “[t]he right to trial by jury is ‘of such importance and occupies so firm a place in our history and jurisprudence that any seeming curtailment of the right’ has always been and ‘should be scrutinized with the utmost care.'” After some discussion of the right to a trial by jury’s roots in common law, Roberts explains that:
In sum, the civil penalties in this case are designed to punish and deter, not to compensate. They are therefore “a type of remedy at common law that could only be enforced in courts of law.” […] That conclusion effectively decides that this suit implicates the Seventh Amendment right, and that a defendant would be entitled to a jury on these claims.
The Supreme Court had decided another case in which it considered whether the Seventh Amendment guarantees the right to a jury trial “in the face of Congress’ decision to allow a non-Article III tribunal to adjudicate” a statutory “fraud claim.” The case, Granfinanciera S.A. v. Nordberg, involved a statutory action for fraudulent conveyance. The question was whether the action could be heard without a jury under the public rights exception. The court decided it could not. And so, Roberts says, “Granfinanciera effectively decides this case.”
Justices Sotomayor wrote a sometimes scorching dissent that was joined by Justices Kagan and Jackson. Sotomayor’s chief point is that the public rights exception should and does apply to Jarkesy. The dissent points out that the government has brought many actions like this one without difficulty or objection from her colleagues on the court. While she declines to speculate on the future of the public rights doctrine, she says:
Less uncertain, however, are the momentous consequences that flow from the majority’s insistence that the Government’s rights to civil penalties must now be tried before a jury in federal court. The majority’s decision, which strikes down the SEC’s in-house adjudication of civil-penalty claims on the ground that such claims are legal in nature and entitle respondents to a federal jury, effects a seismic shift in this Court’s jurisprudence. Indeed, “[I]f you’ve never heard of a statute being struck down on that ground,” and you recall having read countless cases approving of that arrangement, “you’re not alone.”
She is correct. Jarkesy may well put the last nail in the coffin of the SEC’s administrative proceedings and ALJs. Currently, the agency has only two ALJs, down from five just a few years ago. Perhaps the Commission has resigned itself to bringing all of its enforcement actions in federal district court for the foreseeable future. But it is not the only agency that will feel the effect of the Jarkesy decision. Many others engage in administrative adjudication overseen by ALJs. The Social Security Administration employs more than 1,500 of them. It and all the rest will be making adjustments in the near future. The SEC, at least, has a head start.
Sotomayor notes, as she has in a few other dissents, that Jarkesy—and, though she doesn’t say so here, the end of the Chevron doctrine—is a victory for those who wish to destroy the “administrative state.” Quoting herself, she says darkly:
Make no mistake: Today’s decision is a power grab. Once again, “the majority arrogates Congress’s policymaking role to itself.” […] It prescribes artificial constraints on what modern-day adaptable governance must look like. In telling Congress that it cannot entrust certain public-rights matters to the Executive because it must bring them first into the Judiciary’s province, the majority oversteps its role and encroaches on Congress’s constitutional authority. […] Judicial aggrandizement is as pernicious to the separation of powers as any aggrandizing action from either of the political branches.
The next few years will be interesting.
For further information about this securities law blog, please contact Brenda Hamilton, Securities Attorney, at 200 E. Palmetto Park Rd, Suite 103, Boca Raton, Florida, (561) 416-8956, or by email at [email protected]. This securities law blog post is provided as a general informational service to clients and friends of Hamilton & Associates Law Group and should not be construed as and does not constitute legal advice on any specific matter, nor does this message create an attorney-client relationship. Please note that the prior results discussed herein do not guarantee similar outcomes.
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