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This property, called collateral, is then held by either the debtor or the secured party to ensure against loss in the event the debtor cannot fulfill the obligations under the transacti

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limitations to apply in a section 1983 case, the Supreme Court has held that in the interests of national uniformity and predictability, all sec-tion 1983 claims shall be treated as tort claims for the recovery of personal injuries (Wilson v

Garcia, 471 U.S 261, 105 S Ct 1938, 85 L Ed

2d 254[1985]) If the state has various statutes

of limitations for different intentional torts, the Supreme Court mandates that the state’s general

or residualPERSONAL INJURYstatute of limitations should apply (Owens v Okure, 488 U.S 235,

109 S Ct 573, 102 L Ed 2d 594[1989])

When a state does not specifically recognize

a CAUSE OF ACTIONbrought under section 1983, courts look to analogous state laws to determine when the cause of action would accrue In Wallace v Kato, 549 U.S 384, 127 S.Ct 1091,

166 L.Ed.2d 973 (2007), an arrestee brought an action under section 1983, alleging that city police detectives had unlawfully arrested him

Illinois did not recognize unlawful arrest as a tort, so the Court looked to the state’s statute of limitations for FALSE IMPRISONMENT After con-cluding that the claim’s limitations period would have expired under state law, the Court ruled that the arrestee’s claim had expired

The Supreme Court has also held that state tolling statutes, which provide a plaintiff with an additional period of time in which to bring a lawsuit equal to the period of time in which the plaintiff was legally disabled, apply to section

1983 cases (Board of Regents v Tomanio, 446 U.S

478, 100 S Ct 1790, 64 L Ed 2d 440[1980])

Under section 1983, the statute of limitations does not begin to run until theCAUSE OF ACTION

accrues The cause of action accrues when“the plaintiff knows or has reason to know of the injury which is the basis of the action” (Cox v

Stanton, 529 F.2d 47 [4th Cir 1975]) However, in

EMPLOYMENT LAW cases, the Supreme Court has held that the cause of action accrues when the discriminatory act occurs (Delaware State College

v Ricks, 449 U.S 250, 101 S Ct 498, 66 L Ed 2d

431 [1980]) Thus, if an employee is being terminated for reasons that violate section 1983, the statute of limitations begins on the day that the employee learns of the termination, not when the termination actually begins (Chardon v

Fernandez, 454 U.S 6, 102 S Ct 28, 70 L Ed

2d 6[1981])

The legal rules ofRES JUDICATA(claim preclu-sion) and COLLATERAL ESTOPPEL (ISSUE PRECLUSION) apply to section 1983 claims This means that

federal courts must give state court judgments the same preclusive effect that the law of the state in which the judgment was rendered would give Plaintiffs need to be careful to raise all potential federal claims in cases brought in state court because they will not be allowed to bring those claims later in federal court after the state court has rendered a decision on the issues before it

A plaintiff may waive his or her right to sue under section 1983, but such a waiver may be deemed unenforceable if “the interest in its enforcement is outweighed in the circumstances

by aPUBLIC POLICYharmed by enforcement of the agreement” Town of Newton v Rumery, 480 U.S

386, 107 S Ct 1187, 94 L Ed 2d 405[1987] FURTHER READINGS

“Federal Courts—Prisoner Litigation—Eleventh Circuit Holds That a §1983 Action for DNA Access Is Not the Equivalent of a Habeas Corpus Petition ” 2003 Harvard Law Review 116 (June).

Hayman, Robert L 2002 Jurisprudence St Paul, Minn.: West Schwartz, Martin A., and John E Kirklin 2003 Section 1983 Litigation: Claims and Defenses 4th ed New York: Aspen Publishers.

Schwartz, Martin A., and George C Pratt 2009 Section 1983 Litigation: Jury Instructions 2d ed Austin, Tex.: Wolters Kluwer.

Young, Gary 2003 “9th Sees No Regulatory Relief in

§1983 ” National Law Journal (July 21).

CROSS REFERENCES Civil Rights; Remedy; Tort Law.

SECURE

To assure the payment of a debt or the performance

of an obligation; to provide security

A debtor“secures” a creditor by giving him

or her a lien, mortgage, or other security to be used in case the debtor fails to make payment

SECURED CREDITOR

A category of favored creditor who holds some special legal assurance of payment of a debt owed to him or her, such as a type of mortgage or lien, as the result of a specific agreement to that effect The secured creditor, as distinguished from an unse-cured creditor, holds an advantage known as a

“security interest,” which it can assert in order to claim payment as needed The collateral tends to be valued at an amount sufficient to cover the debt, should collection ultimately become necessary The collateral tends to be valued at an amount sufficient to cover the debt, should col-lection ultimately become necessary Colcol-lection

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may occur by compelling a sale (e.g., at auction)

or by keeping or taking repossession of the

collateral in question, in the event of default of

payment In the event of bankruptcy, the

secured creditor enjoys the prospect of being

ahead of unsecured creditors in order of

payment (in case there are any assets with

which to pay the debts)

In order for the security interest to be fully

operational, it often must be “perfected,” or

registered formally with a governmental entity,

such as a financing statement filed publicly with

the office of the secretary of state in the

jurisdiction where the collateral is located The

effect of perfection is to put other potential

creditors on notice as to the secured creditor’s

position with regard to the particular assets In

most states, security interests are governed by

Article 9 of the Uniform Commercial Code

FURTHER READING

Hagedorn, Robert B 2007 Secured Transactions in a

Nutshell 4th ed St Paul, Minn.: West.

SECURED TRANSACTIONS

Secured transactions are business dealings that

grant a creditor a right in property owned or held

by a debtor to assure the payment of a debt or the

performance of some obligation

A secured transaction is a transaction that is

founded on a security agreement A security

agreement is a provision in a business

transac-tion in which the obligor, or debtor, in the

agreement gives to the creditor the right to own

property owned or held by the debtor This

property, called collateral, is then held by either

the debtor or the secured party to ensure against

loss in the event the debtor cannot fulfill the

obligations under the transaction

The purchase of a car through financing is an

example of a secured transaction The car

dealership or some other lender pays for the

vehicle in return for a promise from the buyer to

repay the loan with interest The buyer receives

the vehicle, but the lender retains the title to the

car as security against the risk that the buyer will

be unable to make the loan payments If the

buyer defaults on the payments, the lender,

called the secured party, may repossess the car to

recover losses from the default

If the same transaction was unsecured, the

buyer would receive the title to and possession

of the car, and the lender would receive only the

buyer’s promise to repay the loan If the buyer defaulted on the payments, the lender could sue the buyer, but the simple remedy of taking the property would not be available

A security interest may be transferred, or assigned, to a THIRD PARTY The party receiving the assignment becomes the secured party, and the original secured party no longer holds a claim to the collateral

The law of secured transactions varies little from state to state because all 50 states plus the District of Columbia and the U.S Virgin Islands have adopted Article 9, the secured transactions portion of theUNIFORM COMMERCIAL CODE(UCC)

The UCC is a set of model laws written by lawyers, professors, and other legal professionals

in the American Law Institute In 1999, the institute, in conjunction with the National Conference of Commissioners of Uniform State Laws (NCCUSL), drafted a revised Article 9, which was adopted uniformly on July 1, 2001

The revisions marked the first comprehensive overhaul of Article 9 since 1972 These revisions expand the scope of property and transactions governed by the UCC, clarify existing elements

of the article, and provide guidelines for dealing with technological developments, including software financing andELECTRONIC COMMERCE

Common Forms of Secured Transactions

Secured transactions come in many forms, but three types are most common for consumers:

pledges, CHATTEL mortgages, and conditional sales A pledge is the delivery of goods to the secured party as security for a debt or the performance of an act For example, assume that one person has borrowed $500 from another Assume further that the debtor gives

a piece of expensive jewelry to the creditor If the jewelry is to be returned to the debtor after the debt is repaid, and if the creditor has the right to take full ownership of the jewelry if the debtor does not pay the debt, the arrangement

is called a pledge

ACHATTEL MORTGAGEis like a pledge, but in a chattel mortgage transaction, the debtor is allowed to retain possession of the property that is put up as collateral If the debtor fails to repay the debt, the creditor may take ownership

of the property

A third type of secured transaction, the conditional sale, uses a purchase money security

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interest A purchase money security interest arises when a creditor lends money to a borrower, who uses the money to purchase a particular item To secure repayment of the loan, the creditor receives aLIENon, or claim to, the purchased item The lien gives the creditor a claim to the property that may be asserted if the borrower does not repay the loan

Common Forms of Collateral

Any property accepted as security by a creditor can serve as collateral, but generally collateral falls into one of five categories: consumer goods, equipment, farm products, inventory, and prop-erty on paper Consumer goods are items used primarily for personal, family, or household purposes Equipment consists of items of value used in business or governmental operations

Farm products are items such as crops, livestock,

or supplies used or produced in a farming operation Under the revised Article 9, agricul-tural liens can also be considered collateral

Inventory consists of goods held for sale or lease

or furnished under contracts of service, raw materials, works in process, materials used or consumed in a business, and goods held for sale

or lease or furnished under contracts of service

Paper collateral consists of a writing that serves as evidence of a debtor’s rights in

PERSONAL PROPERTY Stocks and bonds are exam-ples of paper collateral Another common form

of paper collateral is CHATTEL PAPER Chattel paper is a writing that indicates that the holder

is owed money and has a security interest in valuable goods associated with the debt For example, assume that a car dealership has sold a car on financing to a buyer and has retained the title as security The dealership may then use the security agreement with the buyer as collateral for a loan of its own from the bank The revised Article 9 also recognizes “electronic chattel paper.” This allows for the validity of so-called electronic signatures, which Article 9 refers to as

“authenticated records.” The electronic screens

in some retail stores that allow customers to sign with a special stylus are thus just as valid as

a signature in ink on a paper document

Among the new areas governed by the revised Article 9 are commercial deposit accounts, promissory notes, and commercial tort claims Healthcare insurance receivables are also covered, which allows doctors and hospitals

to include claims against insurance companies

for services to their patients as part of the collateral they offer to healthcare lenders

The Formalities

To be valid, a secured transaction must contain

an express agreement between the debtor and the secured party The agreement must be in writing, must be signed by both parties, must describe the collateral, and must contain language indicating a grant of a security interest

to the creditor Furthermore, something of value must be given by one party to the other party This can be a binding commitment to extend credit, the satisfaction of an already existing claim, the delivery and acceptance of goods under a contract, or any other exchange

of value sufficient to create a contract Once these formalities have been completed, the security associated with the principal agreement

is said to attach Attachment simply means that the security side of the agreement is complete and legally enforceable

To completely secure a secured transaction,

or perfect the security, the secured party should file a financing statement with the local public records office, SECRETARY OF STATE, or other appropriate government body Perfecting the security makes the secured party’s claim official, puts the rest of the world on notice as to the creditor’s rights in the property, and gives the creditor the right to take advantage of special remedies in the event the debtor does not repay the loan A financing statement is a document that fully describes the secured transaction The

2000 amendments to Article 9 included a national financing statement form and designated the debtor’s location as the place to file against most tangible and intangible collateral A state may require the secured party to file a financing statement in addition to a copy of the agreement

In most states financing statements are effective only for a limited duration, such as five years ASECURED CREDITOR may extend the length of perfection by filing a continuation statement before the designated time period has expired If a secured creditor fails to continue the perfection, the security is not lost, but other creditors may claim the property The secured creditor may file another financing statement, but this would require another signature from the debtor

Amendments may be made to a financing statement A secured party may file a statement

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of release on some of the collateral once the

debtor has made payments equal in value to the

value of the released collateral If the

amend-ment adds collateral, the security for the new

collateral is effective from the date of the

amendment and not the date of the filing of

the original financing statement

One exception to the filing rule occurs when

the secured party has possession of the

collateral In this situation the creditor’s security

is complete once the parties have agreed to the

primary transaction Another exception is the

purchase money security interest in consumer

goods other than building fixtures and motor

vehicles The filing of a purchase money security

interest for such consumer goods is optional If

a secured party to a conditional sale does not

record or file the agreement, however, he may

lose the security if the buyer sells the goods to a

third party

Failure to perfect the security may have

drastic consequences for the secured party who

does not possess the collateral, although such

failure does not automatically mean that the

security will be lost If, however, another party

later stakes a claim to the collateral and files the

proper papers, the secured party may lose his or

her claim to the property because claims that

have been properly recorded or filed have

priority Thus a secured party is wise to file a

financing statement and other required

docu-ments to perfect the security and protect against

claims by other creditors of the debtor

Article 9 of the UCC is primarily concerned

with protecting the secured party’s right to the

collateral Many sections of Article 9 delineate

who has the first right to a debtor’s property if

multiple claims arise Precisely who has the first

right to the debtor’s property depends on a

number of factors, including whether the

security was perfected, who the other claimant

is, and the time that the claims arose

If a security interest has not been perfected,

the secured party’s claim to the collateral

property may be subordinate to any number

of creditors A person who has a lien on the

property takes before the secured party, as does

a person who has received a court order for

attachment of the property If a person buys the

collateral from the debtor while not knowing of

the security interest, the secured party loses the

property if the security was not perfected This

is true only if the buyer purchases the property

in the ordinary course of business from a person who is in the business of selling goods of that particular kind A pawnbroker, for example, is not such a seller because a pawnbroker will sell almost anything if the profit is worth the time and trouble

The identity of the buyer may influence the outcome of a dispute between a buyer of secured goods and the secured party Generally, a merchant, or a buyer who purchases property for a business, is held to a higher standard than a person who buys an item for personal use

Merchants are more familiar with markets than are ordinary consumers, and they may be expected to know that a seller was insolvent and that the goods being sold were subject to claims from other parties In any case, if any buyer knows that another party has a security interest in the property at the time the buyer made the purchase, the secured party retains the first claim

to the property and may keep the property out of that buyer’s possession until the debt associated with the secured property is fully paid

If two parties have a security interest in the same property, the party who filed first takes first If the competing security interests are both unperfected, the party who was first to attach the property as collateral has priority

Other creditors of a debtor may have the first claim on secured property However, the federal government has priority in some instances for collection of federal tax liens

Most states have artisan’s lien statutes, which give servicers of property the right to hold the property in their possession as security for payment of the service bill If the bill remains unpaid, the servicer has priority even over a secured party who has perfected his or her interest Once a servicer or repairperson is paid for his services, he must release the goods to either their owner or the party with the security interest in the goods

If the debtor to a secured party defaults, the secured party who has failed to perfect the security interest may lose first claim to the secured property to a receiver or an assignee for the benefit of creditors A receiver is a party who

is appointed by theBANKRUPTCYcourt to manage the finances of the debtor for the benefit of the debtor’s creditors An assignee for the benefit of creditors is a person chosen by the debtor to manage all or substantially all of the debtor’s property and to distribute it to creditors

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A secured party who has perfected the security interest has priority over an assignee or a receiver, but even a secured party who has perfected may not receive all of the debt owed under a security agreement by a bankrupt debtor Federal bankruptcy laws are designed

to distribute the assets of an insolvent debtor in

a fair and RATABLE manner among all of the debtor’s creditors

Satisfaction of the Secured Debt

Once a secured debt is repaid in full, the secured party must, upon written request by the debtor, send a termination statement to the debtor and file a termination statement with all offices that hold the financing statement A termination statement serves as evidence that the debt has been paid in full If the debtor makes a written request for the termination statement, the creditor must send the statement within ten days of the date of the request Even if the debtor does not so request, the secured party must send a termination statement to offices that hold the financing statement within 30 days

of the satisfaction of the debt

Default

If a debtor defaults on his obligations under a secured transaction, the secured party may foreclose on the security interest FORECLOSURE

can be accomplished in different ways The secured party may calculate the amount of the debt owed and sue the debtor without taking possession of the property Alternatively, unless the parties have agreed otherwise, the secured party may take possession of the collateral property and either keep it or sell it In either case, if the value received by the secured party does not fully satisfy the debt, the secured party may sue the debtor for the deficiency

In most states a secured party may take possession of the collateral without judicial involvement if doing so can be accomplished without aBREACH OF THE PEACE For example, the secured party may repossess a vehicle if it is parked outdoors If, however, the agent of the secured party must break into a garage to repossess the vehicle, such action would be a breach of the peace because it would require breaking and entering, a criminal offense

If a consumer has defaulted on a secured transaction but has paid 60 percent or more on the debt, most states prohibit a secured party from taking the security and keeping the

windfall In such cases the secured party may either sue in court for the money outstanding or take the property and return part of the money

In other situations a secured party may be entitled to any excess value or income that results from the debtor’s default

The retention of collateral by a secured party after the debtor’s default is called STRICT FORECLOSURE If a secured party decides to keep collateral in satisfaction of a debt, the secured party must send written notice to the debtor In transactions involving collateral other than consumer goods, a secured party may be obliged to send notice of the strict foreclosure

to any other parties who have security in the collateral property If a party objects to the strict foreclosure, the secured party must sell or otherwise dispose of the collateral If no other party objects to the strict foreclosure, the secured party may keep the collateral

A secured party who sells or leases collateral after a debtor defaults may charge the debtor for reasonable expenses incurred in the sale or lease This charge can include attorneys’ fees and court costs The money made from a sale of collateral rarely satisfies a debt because such sales do not bring favorable prices If there is a surplus of money after the collateral is sold, all expenses are accounted for, and the sale or lease

is applied to the debt, other parties holding a security interest in the collateral must be paid with the surplus money

Unless the parties have agreed otherwise, a debtor who is in possession of the collateral and who has defaulted on the obligations in a secured transaction has the right to redeem the collateral before the secured party takes action

To avoid foreclosure of the security interest by the secured party, the debtor may pay the unpaid balance of the debt secured by the collateral, as well as any reasonable expenses incurred by the secured party in taking, holding, and preparing the foreclosure This does not mean the debtor must pay the entire amount of the debt; rather, the debtor must make those payments that are in default Some security agreements have an ACCELERATION CLAUSE that makes all payments due immediately upon default, but a court may hold that such a clause should not be enforced if the debtor has brought the payments up to date before the secured party has acted on the delinquency A secured party who violates default provisions

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may be liable to the debtor for losses resulting

from that conduct

FURTHER READINGS

Brook, James 2002 Secured Transactions: Examples and

Explanations 2d ed New York: Aspen Law & Business.

Dalton, Elizabeth 1986 “The Consequences of

Commer-cially Unreasonable Dispositions of Collateral: Haggis

Management, Inc v Turtle Management, Inc.” Utah Law

Review.

Epstein, David G., Steve H Nickles, and Edwin E Smith.

2003 Nine Questions: Secured Debt Deals in the 21st

Century St Paul, Minn.: Thomson/West.

Huffaker, John 2000 “Good News and Bad News: Revisions

to UCC Article 9 ” Texas Banking (August).

CROSS REFERENCES

Attachment; Bankruptcy; Collateral; Consumer Credit;

Express; Obligor; Security; Sales Law.

SECURITIES

Securities are evidence of a corporation’s debts or

property

Securities are documents that merely

repre-sent an interest or a right in something else; they

are not consumed or used in the same way as

traditional consumer goods Government

regula-tion of consumer goods attempts to protect

consumers from dangerous articles, misleading

advertising, or illegal pricing practices Securities

laws, by contrast, attempt to ensure that investors

have an informed, accurate idea of the type of

interest they are purchasing and its value

Types of securities include notes, stocks,

treasury stocks, bonds, debentures, certificates

of interest or participation in profit-sharing

agreements, collateral-trust certificates,

preorga-nization certificates or subscriptions, transferable

shares, investment contracts, voting-trust

certifi-cates, certificates of deposit for a security, and a

fractional undivided interest in gas, oil, or other

mineral rights Under certain circumstances,

interests in oil- and gas-drilling programs,

interests in partnerships, REAL ESTATE

CONDOMI-NIUMS AND COOPERATIVES, and farm animals and

land also have been found to be securities

Certain types of notes, such as a note secured

by a home mortgage or a note secured by

accounts receivable or other business assets, are

not securities

Both federal and state laws regulate

securi-ties Before 1929, companies could issue stock at

will Bogus corporations sold worthless stock;

other companies issued and sold large amounts

of stock without considering the effect of

unlimited issues on shareholders’ interests, the value of the stock, and ultimately the U.S

economy Federal securities law consists of a handful of laws passed between 1933 and 1940,

as well as legislation enacted in 1970 The federal laws stem from Congress’s power to regulate interstate commerce Therefore, the laws are generally limited to transactions involving transportation or communication using interstate commerce or the mail Federal laws are generally administered by theSECURITIES AND EXCHANGE COMMISSION (SEC), established

by the Securities Exchange Act of 1934 (15 U.S.C.A §§ 78a et seq.) Securities regulation focuses mainly on the market for common stocks The SARBANES-OXLEY ACT OF2002 (Public Company Accounting Reform and Investor Protection Act), Pub L 107-204, 116 Stat

745, makes securities FRAUD a serious federal crime and also increases the penalties for white-collar crimes In addition, it created an oversight board for the accounting profession

Securities are traded on markets Some, but not all, markets have a physical location The essence of a securities market is its formal or informal communications systems whereby buyers and sellers make their interests known and execute transactions These trading markets are susceptible to manipulative and deceptive practices, such as manipulation of prices or

“insider trading,” that is, gaining an advantage

on the basis of nonpublic information To prevent such fraudulent practices, all securities laws contain general antifraud provisions

Exchange markets, of which the New York Stock Exchange is the largest, have traditionally operated in a rigid manner by careful delinea-tion of numbers and qualificadelinea-tions of members and the specific functions members may perform Conversely, over-the-counter markets (OTC) are less structured and typically do not have a physical location

Based upon dollar volume, the bond market

is the largest Bonds are the debt instruments issued by federal, state, and local government, as well as corporations The bond market attracts mainly professional and institutional investors, rather than the general public In addition, many of these obligations are exempt from direct regulatory provisions of the federal securities laws and consequently usually receive little attention from SEC regulators However,

in the mid-1980s, a debacle occurred in theJUNK

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BOND market, which included INSIDER TRADING

charges (Junk bonds are highly risky bonds with

a high yield.) The scandal, which involved the investment firm of Drexel Burnham Lambert Inc and trader Michael R Milken, attracted much attention and a flurry of SEC enforce-ment activity

Securities Act of 1933

The first significant federal securities law was the Securities Act of 1933 (15 U.S.C.A §§ 77a

et seq.), passed in the wake of the great STOCK MARKET crash of 1929 This law is essentially a disclosure statute Although the 1933 act applies

by its terms to any sale by any person of any security, it contains a number of exemptions

The most important exemption involves securi-ties sold in certain kinds of transactions, including transactions by someone other than

an issuer, underwriter, or dealer In essence, this provision effectively exempts almost all second-ary trading, which involves securities bought and sold after their original issue Certain small offerings are also exempt

Although the objective of the 1933 act’s registration requirements is to enable a pro-spective purchaser to make a reasoned decision based on reliable information, this goal is not always accomplished For example, an issuer may be reluctant to divulge real weaknesses in

an operation and so may try to obfuscate some

of the problems while complying in theory with the law In addition, complex financial infor-mation can be extremely difficult to explain in terms understandable to the average investor

Disclosure is accomplished by the registration

of security offerings In general, the law provides that no security may be offered or sold to the public unless it is registered with the SEC

Registration does not imply that the SEC approves of the issue but is intended to aid the public in making informed and educated deci-sions about purchasing a security The law delineates the procedures for registration and specifies the type of information that must be disclosed

The registration statement has two parts:

first, information that eventually forms the prospectus, and second, information, which does not need to be furnished to purchasers but is available for public inspection within SEC files Full disclosure includes management’s aims and goals; the number of shares the

company is selling; what the issuer intends to

do with the money; the company’s tax status; contingent plans if problems arise; legal stand-ing, such as pending lawsuits; income and expenses; and inherent risks of the enterprise

A registration statement is automatically effective 20 days after filing, and the issuer may then sell the registered securities to the public Nevertheless, if a statement on its face appears incomplete or inaccurate, the SEC may refuse to allow the statement to become effective A misstatement or omission of a material fact may result in the registration’s suspension Although the SEC rarely exercises these powers, it does not simply give cursory approval to registration statements The agency frequently issues“letters

of comment,” also known as “deficiency letters,” after reviewing registration documents The SEC uses this method to require or suggest changes or request additional information Most issuers are willing to cooperate because the SEC has the authority to permit a registra-tion statement to become effective less than

20 days after filing The SEC will usually accelerate the 20-day waiting period for a cooperative issuer

For many years an issuer was entitled only

to register securities that would be offered for sale immediately Since 1982, under certain circumstances an issuer has been permitted to register securities for a quick sale at a date up to two years in the future This process, known as shelf registration, enables companies that fre-quently offer debt securities to act quickly when interest rates are favorable

The 1933 act prohibits offers to sell or to buy before a registration is filed The SEC takes

a broad view of what constitutes an offer For example, the SEC takes the position that excessive or unusual publicity by the issuer about a business or the prospects of a particular industry may arouse such PUBLIC INTEREST that the publicity appears to be part of the selling effort

Offers but not sales are permitted, subject to certain restrictions, after a registration statement has been filed but before it is effective Oral offers are not restricted Written information may be disseminated to potential investors during the waiting period via a specially designed prelimi-nary prospectus Offers and sales may be made to anyone after the registration statement becomes

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effective A copy of the final prospectus usually

must be issued to the purchaser

The 1933 act provides for civil liability for

damages arising from misstatements or

omis-sions in the registration statement or for offers

made in violation of the law In addition, the

law provides for civil liability for misstatements

or omissions in any offer or sale of securities,

whether or not the security is registered Finally,

the general antifraud provision in the law

makes it unlawful to engage in fraudulent or

deceitful practices in connection with any offer

or sale of securities, whether or not they are

registered

In general, any person who acquires an

equity whose registration statement, at the time it

became effective, contained an“untrue statement

of a material fact or omitted to state a material

fact” may sue to recover the difference between

the price paid for the security (but not more than

thePUBLIC OFFERINGprice) and the price for which

it was disposed or (if it is still owned) its value at

the time of the lawsuit A purchaser must show

only that the registration statement contained a

material misstatement or omission and that he

or she lost money In many circumstances the

purchaser need not show that he or she relied on

the misstatement or omission or that a

prospec-tus was even received The SEC defines material

as information an average prudent investor

would reasonably need to know before

purchas-ing the security

Securities Exchange Act of 1934

The Securities Exchange Act of 1934 addresses

many areas of securities law Issuers, subject to

certain exemptions, must register with the SEC

if they have a security traded on a national

exchange This requirement should not be

confused with the registration of an offering

under the 1933 act; the two laws are distinct

Securities registered under the 1933 act for a

public offering may also have to be registered

under the 1934 act

To provide the public with adequate

infor-mation about companies with publicly traded

stocks, issuers of securities registered under the

1934 act must file various reports with the SEC

Since 1964 this disclosure requirement has

applied not only to companies with securities

listed on national securities exchanges but also

to companies with more than 500 shareholders

and more than $5 million in assets False

or misleading statements in any documents required under the 1934 act may result in liability to persons who buy or sell securities in reliance on these statements

Under the 1934 act, the SEC may revoke or suspend the registration of a security if after notice and opportunity for hearing it determines that the issuer has violated the 1934 act or any rules or regulations promulgated thereunder

Moreover, the 1934 act authorizes the SEC to suspend trading in any security for not more than ten days, or, with the approval of the president, to suspend trading in all securities for not more than 90 days, or to take other measures

to address a major market disturbance

Proxy Solicitation The 1934 act also regulates

PROXY solicitation, which is information that must be given to a corporation’s shareholders as a prerequisite to soliciting votes Prior to every shareholder meeting, a registered company must provide each stockholder with a proxy statement containing certain specified material, along with a form of proxy on which the security holder may indicate approval or disapproval of each proposal expected to be presented at the meeting

For securities registered in the names of brokers, banks, or other nominees, a company must inquire into the beneficial ownership of the securities and furnish sufficient copies of the proxy statement for distribution to all the beneficial owners

Copies of the proxy statement and form of proxy must be filed with the SEC when they are first mailed to security holders Under certain circumstances preliminary copies must be filed ten days before mailing Although a proxy statement does not become effective in the same way as a statement registered under the 1933 act, the SEC may comment on and require changes in the proxy statement before mailing Proxies for

an annual meeting calling for election of directors must include a report containing financial statements covering the previous two fiscal years

Special rules apply when a contest for election or removal of directors is scheduled

A security holder owning at least $1,000,

or 1 percent, of a corporation’s securities may present a proposal for action via the proxy statement Upon a shareholder’s timely notice

to the corporation, a statement of explanation is included with the proxy statement Security holders will have an opportunity to vote on the proposal on the proxy form The device is

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unpopular with management, but shareholders have used this provision to change or challenge management compensation, the conduct of annual meetings, shareholder voting rights, and issues involving DISCRIMINATION and pollu-tion in company operapollu-tions

A company that distributes a misleading proxy statement to its shareholders may incur liability to any person who purchases or sells its securities based on the misleading statement

The U.S Supreme Court has held that an omitted fact is material if a “substantial likelihood” exists that a reasonable shareholder would consider the information important in deciding how to vote Mere NEGLIGENCE is sufficient to permit recovery; no evil motive or reckless disregard need be shown Oftentimes,

an appropriate remedy might be a PRELIMINARY INJUNCTION requiring circulation of corrected materials; it may not be feasible to rescind a tainted transaction after voting Courts have, however, sometimes ordered a new election of directors, but such action must be in the best interests of all shareholders

Takeover Bids and Tender Offers Since the 1960s, increasing numbers of takeover bids and tender offers have resulted in bitter contests between the aggressor and the target of the bid

A corporate or individual aggressor might attempt to acquire controlling stock in a publicly held corporation in a number of ways: by buying

it outright for cash, by issuing its own securities in exchange, or by a combination of both methods

Stock may be acquired in private transactions, by purchases through brokers in the open market, or

by making a public offer to shareholders to tender their shares either for a fixed cash price or for

a package of securities from the corporation making the offer

Takeover bids that involve a public offer for securities of the aggressor company in exchange for shares of the targeted company require that the securities be registered under the 1933 act and that a prospectus be delivered to solicited shareholders For many years, however, cash tender offers had no SEC filing requirements

The WILLIAMS ACT of 1968 (15 U.S.C.A §§ 78l, 78m, 78n) amended many sections of the 1934 act to address problems with tender offers

Although most LITIGATION under the Williams Act is between contending parties, courts generally focus on whether the relief sought serves to protect public stockholders

Pursuant to the Williams Act, any person

or group who takes ownership of more than

5 percent of any class of specific registered securities must file a statement within ten days with the issuer of the securities, as well as with the SEC Required information includes the background of the person or group; the source

of funds used and the purpose of the acquisi-tion; the number of shares owned; and any relevant contracts, arrangements, or under-standings The issue of whether an acquisition has taken place, thereby triggering the filing requirement, has been the subject of litigation Courts have disagreed on this issue when confronted with a group of shareholders who

in the aggregate own more than 5 percent and who agree to act together for the purpose of affecting control of the company but who do not act to acquire any more shares

Restrictions also apply to persons making a

TENDER OFFERthat would result in ownership of more than 5 percent of a class of registered securities Such a person must first file with the SEC and furnish to each offeree a statement similar to that required of a person who has obtained more than 5 percent of registered stock A tender offer must be held open for

20 days; a change in the terms holds an offer open at least ten more days In addition, the offer must be made to all holders of the class of securities sought, and a uniform price must be paid to all tendering shareholders A share-holder may withdraw tendered shares at any time while the tender offer remains open Moreover, if the person making the offer seeks fewer than all outstanding shares and the response is oversubscribed, shares will be taken

up on aPRO RATAbasis

The 1934 act also requires every person who directly or indirectly owns more than 10 percent

of a class of registered equity securities, and every officer and director of every company with a class of equity securities registered under that section, to file a report with the SEC at the time he acquires the status, and at the end of any month in which he acquires or disposes of these securities This provision is designed to prevent short-swing profits, earned when an individual with inside information engages in short-term trading

Antifraud Provisions One impetus for enact-ment of the 1934 act was the damage caused by pools, which were a device used to run up the

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prices of securities on an exchange The pool

would engage in a series of well-timed

transac-tions, designed solely to manipulate the market

price of a security Once prices were high, the

members of the pool unloaded their holdings

just before the price dropped The 1934 act

contains specific provisions prohibiting a variety

of manipulative activities with respect to

exchange-listed securities It also contains a

catchall section giving the SEC the power to

promulgate rules to prohibit any“manipulative

or deceptive device or contrivance” with respect

to any security Although isolated instances of

manipulation still exist, the provisions manage

to prevent widespread problems

Section 10(b) of the 1934 act contains a

broadly worded provision permitting the SEC to

promulgate rules and regulations to protect the

public and investors by prohibiting

manipula-tive or decepmanipula-tive devices or contrivances via the

mails or other means of interstate commerce

The SEC has promulgated a rule, known as rule

10b-5, that has been invoked in countless SEC

proceedings The rule states:

It shall be unlawful for any person,

directly or indirectly, by use of any means or

instrumentality of interstate commerce, or of

the mails, or of any facility of any national

securities exchange, (1) to employ any

device, scheme, or artifice to DEFRAUD, (2)

to make any untrue statement of a material

fact or to omit to state a material fact

necessary in order to make the statements

made, in light of circumstances under which

they were made, not misleading, or (3) to

engage in any act, practice, or course of

business which operates or would operate as

a fraud or deceit upon any person, in

connection with the purchase or sale of any

security

In the 1960s and early 1970s, the courts

broadly interpreted rule 10b-5 For example, the

rule was applied to impose liability for negligent

misrepresentations and for breach of FIDUCIARY

duty by corporate management and to hold

directors, lawyers, accountants, and

underwri-ters liable for their failure to prevent

wrongdo-ing by others Beginnwrongdo-ing in 1975, the U.S

Supreme Court sharply curtailed this broad

reading Doubt exists as to the continued

viability of the decisions in some of the prior

cases Nevertheless, although rule 10b-5 does

not address civil liability for a violation, since

1946 courts have recognized an implied private

RIGHT OF ACTION in rule 10b-5 cases, and the

Supreme Court has acknowledged this implied right (Superintendent v Bankers Life, 404 U.S 6,

30 L Ed 2d 128, 92 S Ct 165[1971])

Rule 10b-5 applies to any purchase or sale,

by any person, of any security There are no exemptions: it applies to registered or unregis-tered securities, publicly held or closely held companies, and any kind of entity that issues securities, including federal, state, and local government securities

Clauses 1 and 3 of rule 10b-5 use the terms fraud and deceit Fraud or deceit must occur “in connection with” a purchase or sale but need not relate to the terms of the transaction For example, in Superintendent v Bankers Life, the U.S Supreme Court found a violation of rule 10b-5 when a group obtained control of an insurance company then sold certain securities and misappropriated the proceeds for their own benefit In another case a publicly held corporation made misstatements in a press release Even though the company was not engaged at that time in buying or selling its own shares, a U.S court of appeals ruled that the statements were made “in connection with”

purchases and sales being made by shareholders

on the open market

Insider Trading Rule 10b-5 protects against insider trading, which is a purchase or sale by a person or persons with access to information not available to those with whom they deal or to traders generally Originally, the prohibition against insider trading dealt with purchases by corporations or their officers without disclosure

of material, favorable corporate information

Beginning in the early 1960s, the SEC broad-ened the scope of the rule The rule now operates as a general prohibition against any trading on inside information in anonymous stock exchange transactions, in addition to traditional face-to-face proceedings For exam-ple, in In re Cady, Roberts & Co., 40 S.E.C 907 (1961), a partner in a brokerage firm learned from the director of a corporation that it intended to cut its dividend Before the news was generally disseminated, the broker placed orders to sell the stock of some of his customers In another case officers and employ-ees of an oil company made large purchases of company stock after learning that exploratory drilling on some company property looked extremely promising (SEC v Texas Gulf Sulphur, 401 F 2d 833 [2d Cir 1968]) In these

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