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pantherj

12/27/09 7:32 PM

#272457 RE: puppydotcom #272449

Looks to me like SPNG would rank as pretty high priority based a at least the following:

whether an action would fulfill a programmatic goal of the SEC or the
Division
• whether an action would address a problematic industry practice
• whether an action would present a good opportunity to coordinate with other
civil and criminal agencies
5
• whether the conduct can be addressed by any other state or federal regulators
•• the magnitude of the potential violations involved in the investigation,
considering:
o the egregiousness of the conduct
o the length of time the conduct continued, or whether it is ongoing
o the number of violations
o whether violations were repeated
o the amount of harm or potential harm to victims
o the amount of ill-gotten gains to the violators
o whether victims were specifically targeted based on personal or affinity
group characteristics
o for issuers or regulated entities, whether the conduct involved officers,
directors, or senior management
• the resources required to investigate the potential violations, considering:
o the complexity of the potential violations