It's not a theory, reversetaxman.
I have studied a few hundred SEC Suspensions, Administrative Proceedings, SEC Litigations, and Court Ordered revocations.
An SEC Suspension is never predicated on theories, rather on overwhelming evidence of Securities Violations.
Only a Court can determine guilt or innocence if the SEC files civil charges against any Security et al. The DOJ / FBI / and other Law Enforcement Agencies are responsible for filing any criminal charges concomitant to the SEC civil charges against any public Security, when warranted.
The SEC isn't kidding around.
To bite the worm of incite is to bite the HOOK of the antagonist . They win .