David Frankel

David Frankel

Kramer Levin Naftalis & Frankel LLP

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Tenth Circuit Decision in Bandimere v. SEC Creates Circuit Split on Question Whether the SEC’s Procedure for Appointing...

On December 27, 2016, in Bandimere v. SEC, the Tenth Circuit held that SEC administrative law judges (ALJs), who preside over the agency’s civil administrative proceedings, are “inferior officers” within the meaning of the...more

1/11/2017  /  Administrative Appointments , Administrative Law Judge (ALJ) , Appointments Clause , Securities and Exchange Commission (SEC) , Split of Authority
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