Stop Orders
Chapters in this video
- 0:00 The two-part test: public interest and statutory ground
- 1:30 The grounds for stoppage: incomplete statements to coordination failures
- 3:53 Summary suspension versus final stop order: due process distinctions
- 5:06 The ticking clocks: 30 days, 1 year, and 15 days
- 7:11 Stop orders as investor protection tools, not penalties
- 7:30 Rapid-fire exam recap
What this video covers
- The two requirements for any stop order: public interest finding plus a specific statutory ground, not either-or
- Each statutory ground including incomplete or misleading statements, willful violations, other stop orders or injunctions, illegal business activities, fraud, unfair or inequitable terms, unreasonable compensation, filing ineligibility, coordination undertaking failure, and unpaid filing fees
- Why an unpaid filing fee triggers only a denial order that is automatically vacated upon payment, not revocation
- The key distinction between summary suspension (immediate, no prior hearing required) and a final stop order (requires prior notice, hearing opportunity, and written findings)
- The 30-day time limit to challenge an effective registration based on facts known at effectiveness, and why later-discovered facts are exempt
- The 1-year limit to piggyback on another state's stop order or injunction against an effective registration
- The 15-day deadline to set a hearing after receiving a written request following summary suspension
- Why stop orders are administrative tools for investor protection, not punitive penalties
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