SEC Sues Lawyer for Altering PPMs in Response to Document Request
The SEC has sued a lawyer for providing doctored PPMs in
response to document production requests as part of an SEC examination. The SEC, concerned that the lawyer’s client
misused offering proceeds, requested copies of the PPMs delivered to
investors. As alleged by the SEC, the
lawyer provided PPMs that he edited to reflect a different use of proceeds than
was described in the actual PPMs delivered to investors. The SEC has charged violations of its rules
of practice as well as various violations of
lawyers. The SEC also cites violations
of the
criminal code for obstruction of justice.
OUR TAKE: Never create or alter documents in response to
SEC requests. It transforms what would
otherwise be an unintentional regulatory problem into an intentional criminal
act.
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