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SEC Reminds Companies: Disclose Risks as Real When They Cease to be Hypothetical

By Case Towslee on July 25, 2019
Posted in 1934 Act Filings, LIBOR, Uncategorized

In a recent settled enforcement action, the SEC provided an important lesson on required public disclosures.[1]  The SEC charged that Facebook disclosed misuse of its user data as a potential or hypothetical risk even though the company knew that user data had actually been misused.

According to the SEC’s…

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