Simpson Thacher Attorneys Author Article on the SEC’s Disgorgement Authority
Partner Adam Aderton and Associate Abigail Grise authored an article titled, “Disgorgement Reconsidered: Rule 105 and the Adviser-Client Divide,” which was published by The Review of Securities & Commodities Regulation. The article detailed how judicial decisions have progressively narrowed the SEC’s disgorgement authority, emphasizing statutory limits and the need for investor-specific harm. The article discusses this development, and the broader questions raised about the future of disgorgement in SEC enforcement.
To read the full article, please click here.