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Petition to Amend the SEC Rule Under Which the Agency Has Been Unconstitutionally Silencing Persons Who Enter Into Consents With the SEC

October 30, 2018
In the News
Pursuant to the Administrative Procedure Act, 5 U.S.C. § 553(e), and Rule 192(a) of the U. S. Securities and Exchange Commission (“SEC” or “Commission”), 17 C.F.R. § 201.192(a), the Petitioner New Civil Liberties Alliance (“NCLA”) hereby petitions the Commission to amend its rule restricting speech that is set forth in 17 C.F.R. § 202.5(e) (“The…
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Petition to Amend: SEC Rule Imposing Speech Restraints in Consent Orders

October 30, 2018
In the News
In re SEC Rule Imposing Speech Restraints in Consent Orders The SEC Rule adopts “the policy that in any civil lawsuit brought by it or in any administrative proceeding of an accusatory nature pending before it, it is important to avoid creating, or permitting to be created, an impression that a decree is being entered…
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Comments in Response to the Bureau of Consumer Financial Protection: Request for Information Regarding Bureau Guidance and Implementation Support

July 2, 2018
In the News
Re: Request for Information Regarding Bureau Guidance and Implementation Support, Docket No. CFPB-2018-0013 NCLA sincerely appreciates this opportunity to provide commentary on the Bureau’s past use of guidance and its invitation for suggestions as to how it can ensure that its future guidance adheres to law. Unfortunately, the Bureau’s past use of guidance has been…
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