Law360, New York (July 6, 2015, 10:17 AM EDT) -- Over the last several years, in the wake of changes to the securities laws brought about by the Dodd-Frank Act and the Jobs Act, the U.S. Securities and Exchange Commission has been increasingly targeting persons who participate in the marketing or sale of securities for enforcement action, typically claiming that the person's involvement in the securities sale requires registration as a broker-dealer under Section 15(a)(1) of the Securities Exchange Act of 1934, as amended. Section 15(a)(1) enforcement actions by the SEC are nothing new, but the frequency of the enforcement actions, the severity of the penalties, and the lack of investor harm or allegations of fraud signal a new approach by the SEC to enforcement in this area....
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