In an article titled, "SEC's 'Broken Windows' Gambit Leaves No Room For Error," Joseph Dever, a member of Cozen O'Connor's Commercial Litigation Department, discusses the SEC's broken window policy, which is based on the premise that no securities law violation is too small to prosecute and that minor enforcement actions lead to greater overall compliance. "You see press releases now touting enforcement actions that involve either no or negligible investor harm, low dollar amounts for insider trading, and these are cases that the SEC a couple of years ago certainly would not have touted in a press release," observed Joseph.
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