Stop Orders for Securities Registrations
Chapters in this video
- 0:00 The administrator's three stop powers
- 1:47 The two-prong test (both mandatory)
- 3:07 Nine statutory grounds, intent, and absurd examples
- 4:34 The filing-fee trap (denial only, vacate on payment)
- 5:11 The 30-day retroactive limit for known facts
- 6:18 Summary postponement versus normal due process
- 7:41 The 15-day hearing request window
- 8:06 Rapid-fire exam recap
What this video covers
- Why both the public interest prong and a specific statutory ground are mandatory for any valid stop order, and why either prong failing defeats the order
- The three forms of stop order power (denial, suspension, and revocation of effectiveness) and how they apply across all three registration methods: notification, coordination, and qualification
- The nine statutory grounds for stop orders, with special attention to the filing-fee ground (denial only, must be vacated on payment) versus all other grounds
- Why willful violation requires intent, and how the false or incomplete filing ground covers inadvertent errors instead
- The 30-day retroactive limitation on acting against effective registrations based on facts known at the time of effectiveness, and why this period is identical for securities and person registrations
- How summary postponement allows immediate suspension without prior notice or hearing, and the 15-day window to set a hearing after written request
- Why failure to request a hearing leaves a summary postponement in effect indefinitely, and the procedural contrast with normal due process (notice, hearing, and written findings first)
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