Aug. 5, 2014
Today, I am issuing my opinion in the Matter of John W. Lawton, SEC Administrative Proceeding File No. 3-14162, concurring in part and dissenting in part from the Commission’s majority opinion with respect to the bars from association with municipal advisors and nationally recognized statistical rating organizations (“NRSROs”). While I concur with the judgment in this matter, I respectfully disagree with the majority’s retroactive application of such bars to conduct that predated their creation.