Lot of homework
The Wells notices advised that the Commission Staff intends to recommend that the Commission bring civil injunctive actions against them alleging violations of the federal securities laws contained in Sections:
1) 5(a),
2)5(c) and
3)17(a) of the Securities Act of 1933, as amended (“Securities Act”) and
4)Sections 10(b),
5) 13(b)(5) of the Exchange Act of 1934, as amended (“Exchange Act”) and
6) Exchange Act Rules 10b-5,
7) 13b2-1, and
8) 13b2-2 thereunder; and
9)Sections 13(a),
10) 13(b)(2)(A), and
11) 13(b)(2)(B) of the Exchange Act and
12) Exchange Act Rules 12b-20,
13) 13a-1,
14) 13a-11,
15) 13a-13, and
16) 13a-14 thereunder.
The recommended actions would seek, among other things, permanent injunctions and civil penalties.