There's little doubt the SEC (and FINRA) has playe
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The hand of the new SEC Chair Mary Jo White (April 2013) is evident. It used to be the SEC would primarily focus on the more egregious cases of misconduct and fraud, cases that harvested the big fines and disgorgements. Now, the SEC is also hammering on the little stuff per Ms. White's directives and initiatives.
The good news is Chair White seems quite sincere in her vow to protect the investing public from microcap malefactors, the bad women and men in the microcap universe who prey on the inexperience and gullibility of small investors. To that end, White set up an aggressive 26-member team called the Microcap Task Force. http://www.sec.gov/spotlight/microcap-fraud.shtml They get bonuses for bagging microcap malefactors and, by all accounts, they're hungry.
The bad news is for those firms and their facilitators (who Chair White calls 'gatekeepers') who play fast and loose on the OTC in respect to financial operations, control issues, public statements etc.
White has made it clear the SEC will act both pro-actively and pre-emptively, and that the focus of the SEC on wayward activities in the microcrap universe will remain and intensify.