![](https://clsbluesky.law.columbia.edu/wp-content/uploads/sites/2/2022/01/park-e1643319393601.jpg?w=150&h=172&crop=1)
Karmel’s Dissent: The SEC’s Use and Occasional Misuse of Reports of Investigation
A small number of investigations by the Securities and Exchange Commission (SEC) end with the filing of a report rather than a complaint or administrative order. Section 21(a) of the Securities Exchange Act of 1934 authorizes the SEC “to publish …