Nope! He is TOTALLY CORRECT.
DBMM. was ordered revoked by ALJ Jason Patil.
Before the revocation could take effect, the SEC Vs. Lucia case decision was handed down. That case called into question the ratification of ALL the ALJ’s that were commissioned at that time. Because of that, each ALJ decision that had been handed down was remanded. The DBMM revocation was one of those. If not for the Lucia decision, DBMM would be a memory only.
The ID decision handed down by Foelak came right out and stated that the OIP allegations WERE PROVEN. She also came out and directly stated that DBMM was in violation of the filing regulations.
She then foolishly stated that she was dismissing the proceeding because (in her opinion) there was no punishment that fit DBMM’s transgressions.
This (in MY opinion) was totally in error. She herself previously handed down revocation orders to MANY other companies that had the EXACT SAME FILING TRANSGRESSIONS that DBMM had. Yet suddenly, revocation doesn’t fit that crime?? BS!
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