September 2, 2018
2. Are there other types of arrangements (e.g., the use of declination letters in cases where the subject company pays all disgorgement, forfeiture amounts and/or restitution resulting from the misconduct at issue) that should be included in any rule the Commission adopts? How would any such arrangements satisfy the statutory requirements that they constitute a judicial or administrative action brought by the Commission or a related-action authority and that they include monetary sanctions (i.e., moniesordered to be paid) that are imposed in the
action?
Yes, the attached.
(Attached File #1: s71618-4295299-173166.pdf)