In a petition for review of the SEC's affirmance of the National Association of Securities Dealers' award of restitution against petitioner-securities representative, the petition is granted where the SEC completely failed to articulate any meaningful standards governing the level of causation required under Principle 5 of the Financial Industry Regulatory Authority Sanction Guidelines.
Argued September 14, 2009
Decided January 12, 2010
Opinion by Judge Edwards
George C. Freeman, III, Washington, DC
Rada Lynn Potts and David M. Becker, Securities and Exchange Commission, Washington, DC