John Grugan

John Grugan

Ballard Spahr LLP

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SEC Issues First MCDC Cease and Desist Order

Yesterday, the Securities and Exchange Commission (SEC) announced its first cease and desist order under its Municipalities Continuing Disclosure Cooperation Initiative (MCDC Initiative). The MCDC Initiative was introduced on...more

7/10/2014 - Cease and Desist Disclosure Requirements MCDC Misrepresentation Municipalities SEC

SEC Announces First Investment Adviser ‘Pay-to-Play’ Enforcement Action

The U.S. Securities and Exchange Commission (SEC) announced its first enforcement action under "pay-to-play" rules for investment advisers since those rules were adopted nearly four years ago. TL Ventures Inc., a...more

6/25/2014 - Campaign Contributions Enforcement Enforcement Actions Fees Investment Adviser PACs Pay-To-Play Pensions Private Equity SEC

SEC Charges Charter School Operator with Disclosure Violations, Suggests It May Charge Individuals

The U.S. Securities and Exchange Commission recently charged a Chicago charter school operator with defrauding investors in a $37.5 million bond offering by failing to disclose transactions that presented conflicts of...more

6/5/2014 - Bonds Charter Schools Disclosure Requirements Fraud SEC

2013 Review: SEC Municipal Market Enforcement Actions

In 2013, the Securities and Exchange Commission sought to demonstrate its resolve in enforcement by bringing more selective cases with a greater yield in financial penalties. Indeed, the SEC recently announced that its 2013...more

1/27/2014 - Compliance EMMA Enforcement Enforcement Actions MSRB SEC

SEC Assesses Its First Financial Penalty against a Municipal Securities Issuer

The Securities and Exchange Commission (SEC) announced yesterday that it has, for the first time, assessed a financial penalty against a municipal securities issuer. The penalty arises from a settled administrative proceeding...more

11/7/2013 - Investors Municipal Bonds Municipal Securities Issuers Penalties SEC

The SEC’s Renewed Focus on Financial Reporting and Accounting Fraud

In several recent public speeches, the Securities and Exchange Commission (SEC) has announced a renewed focus on financial reporting and accounting fraud, vowing to devote substantial resources to enforcement activities in...more

10/29/2013 - Accounting Accounting Fraud Compliance Enforcement Fraud SEC

EB-5 Program Faces Heightened Enforcement Scrutiny

Announcements last week by the Securities and Exchange Commission (SEC) and U.S. Citizenship Immigration Services (USCIS) indicate that investments made through the EB-5 Immigrant Investor Program (the EB-5 Program) will be...more

10/14/2013 - EB-5 Enforcement Actions Fraud Green Cards Investors SEC USCIS Visas

SEC Announces Policy Shift on ‘Neither Admit Nor Deny’ Settlements

Earlier this week, the Securities and Exchange Commission (SEC) announced a policy shift concerning settled enforcement actions. The SEC has indicated that certain defendants will have to admit wrongdoing as a condition of...more

6/21/2013 - Deferred Prosecution Agreements Enforcement Actions Neither Admit Nor Deny Settlements Non-Prosecution Agreements SEC Settlement

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