REGULATORY ENFORCEMENT JURISPRUDENCE

Securities Law Statutory Provisions

The legal pillars under the Securities Act of 1933, Securities Exchange Act of 1934, and Sarbanes-Oxley Act governing accounting fraud, restatements, and auditor discipline.

KEY FACTS
  • Securities enforcement actions rely on distinct statutory provisions that divide strict reporting non-compliance from intentional fraud.
  • Section 13(a) and Section 13(b)(2) require no proof of fraudulent scienter, establishing liability solely upon material financial inaccuracy.
  • Section 10(b) and Rule 10b-5 require establishing severe recklessness or conscious intent to defraud in connection with securities transactions.
Securities Exchange Act of 1934 exchange

Exchange Act § 10(b) / Rule 10b-5

General Anti-Fraud and Manipulative Devices

Makes it unlawful to employ any device, scheme, or artifice to defraud, or to make any untrue statement of a material fact or omit to state a material fact necessary to make statements not misleading in connection with the purchase or sale of securities.

Scienter: Recklessness or Intent (Severe Scienter Required)
Securities Exchange Act of 1934 exchange

Exchange Act § 13(a)

Periodic Financial Reporting Mandate

Requires every issuer of a registered security to file annual reports (Form 10-K) and quarterly reports (Form 10-Q) that contain complete, accurate, and non-misleading financial statements.

Scienter: Strict Liability / Negligence (No Scienter Required)
Securities Exchange Act of 1934 exchange

Exchange Act § 13(b)(2)(A)

Books and Records Accuracy Standard

Requires issuers to make and keep books, records, and accounts which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the issuer.

Scienter: No Scienter Required Against Issuers
Securities Exchange Act of 1934 exchange

Exchange Act § 13(b)(2)(B)

Internal Accounting Controls Requirement

Mandates that public issuers devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that transactions are executed in accordance with management authorization and recorded properly.

Scienter: No Scienter Required Against Issuers
Securities Exchange Act of 1934 exchange

Exchange Act § 13(b)(5)

Circumvention of Controls and Falsification of Books

Prohibits any person from knowingly circumventing or knowingly failing to implement a system of internal accounting controls or knowingly falsifying any book, record, or account.

Scienter: Knowing Circumvention or Intent Required
Securities Act of 1933 securities

Securities Act § 17(a)

Fraud in the Offer or Sale of Securities

Prohibits fraud, untrue statements of material fact, omissions, or deceptive practices in the offer or sale of securities, applying to IPOs, secondary offerings, and private placements.

Scienter: Scienter for § 17(a)(1); Negligence for § 17(a)(2) and § 17(a)(3)
Sarbanes-Oxley Act of 2002 sox

Sarbanes-Oxley § 302

Corporate Responsibility for Financial Reports

Requires principal executive and financial officers (CEO and CFO) to personally certify under oath that periodic reports contain no material misstatements and that internal disclosure controls have been reviewed.

Scienter: Knowledge of Inaccuracy / Willful False Certification
Sarbanes-Oxley Act of 2002 sox

Sarbanes-Oxley § 304

Forfeiture of CEO and CFO Bonuses (Clawback)

Requires CEOs and CFOs of issuers that restate financials due to material noncompliance as a result of misconduct to reimburse the issuer for bonuses, incentive pay, and equity profits received during the 12-month period following the filing.

Scienter: No Personal Misconduct Required for Issuer Misconduct
SEC Rules of Practice sec

SEC Rule of Practice 102(e)

Suspension and Debarment of Accountants and Auditors

Authorizes the Commission to censure or deny, temporarily or permanently, the privilege of appearing or practicing before the Commission to accountants who engage in improper professional conduct or lack character and integrity.

Scienter: Improper Professional Conduct (Negligence or Intent)