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Articles Posted in Sub Rosa Guidance

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SEC Commissioner Fears that Non-Public Guidance from Agency Staffers May Amount to “Secret Law”

In a recent speech, an SEC Commissioner took the opportunity to voice her concern that the prevalence of non-public guidance now being conveyed by SEC staffers to certain market participants and their counsel is tantamount to what she terms “secret law” which, in her opinion, “crosses the line” of propriety.…

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