Yesterday, Acting CFTC Chairman Caroline Pham created a two-week window to bring “reasonable settlement offers” to the commission. Based on my conversations with her and others, I believe the CFTC is in “deal mode” and is...more
The materiality standard in fraud cases may soon shift dramatically if the comments of Supreme Court justices during a recent oral argument are any indication. A rollback of the materiality standard would be the latest in a...more