odd isn't it .. all the demand for transparency from corporations but little given in return from their own *activity* or wall street
Since the SEC does not make its administrative pleadings public we have no way of knowing if this issue has been dealt with in any previous cases. Since SEC appellate briefs and district court pleadings are not readily available we have no way of knowing if the issue has been raised in any civil cases.
From a policy standpoint one has to wonder why the SEC does not specify the maximum penalty amount it seeks in its cases. It certainly would not do any harm to its enforcement objectives if it did so. Its staff will have to propose a specific penalty at some stage of any litigation. Why not do it transparently when it brings a case?