Second Circuit -- VanCook v. SEC

VanCook v. SEC

Both actions in furtherance of late trading and late trading itself run afoul of SEC Rule 10(b).

(Securities are priced by 4PM, some operators managed to trade after 4PM based on 4PM prices.)


Scienter requirement for recordkeeping rule that all orders must be timestamped refers to knowledge of the practice, not knowledge of the law.


Penalties kosher.