Federal Regulatory Agencies
News releases, reports, statements and associated documents from federal regulatory agencies ranging from the Securities Exchange Commission to the Commodities Futures Trading Commission
Featured Stories
Merit Systems Protection Board: Court Decisions
WASHINGTON, Sept. 7 -- The Merit Systems Protection Board issued the following case report for Sept. 6, 2024:
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NONPRECEDENTIAL:
Wilson v. Merit Systems Protection Board, 2024-1355 (https://cafc.uscourts.gov/opinions-orders/24-1355.OPINION.9-5-2024_2379754.pdf) (Fed. Cir. September 5, 2024) (CH-1221-23-0231-W-1) (per curiam).
The court affirmed the Board's decision dismissing the petitioner's individual right of action (IRA) appeal for lack of jurisdiction on the basis that the petitioner's alleged disclosures concerned allegations of discrimination and retaliation for engaging in equal
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WASHINGTON, Sept. 7 -- The Merit Systems Protection Board issued the following case report for Sept. 6, 2024:
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NONPRECEDENTIAL:
Wilson v. Merit Systems Protection Board, 2024-1355 (https://cafc.uscourts.gov/opinions-orders/24-1355.OPINION.9-5-2024_2379754.pdf) (Fed. Cir. September 5, 2024) (CH-1221-23-0231-W-1) (per curiam).
The court affirmed the Board's decision dismissing the petitioner's individual right of action (IRA) appeal for lack of jurisdiction on the basis that the petitioner's alleged disclosures concerned allegations of discrimination and retaliation for engaging in equalemployment opportunity activity, claims over which the Board lacks jurisdiction in an IRA appeal.
McAlman v. Department of the Interior, 2023-2392 (https://cafc.uscourts.gov/opinions-orders/23-2392.OPINION.9-5-2024_2379779.pdf) (Fed. Cir. September 5, 2024) (NY-1221-17-0233-W-1) (per curiam).
The court affirmed the Board's decision denying the petitioner's request for corrective action in her IRA appeal. The court found no error in the Board's findings that, even assuming the petitioner engaged in protected activity in connection with her union grievances, prior complaints to the Office of Special Counsel, and prior Board appeal, she failed to establish that these activities were a contributing factor in the agency's decision to take any of the challenged personnel actions because the officials who took the challenged actions did not have knowledge of the petitioner's protected activities, the allegedly retaliatory personnel actions were too remote in time from the protected activities, or the allegedly retaliatory personnel actions predated the protected activities.
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Original text here: https://www.mspb.gov/decisions/case_reports/Case_Report_September_6_2024.pdf
Litigation: SEC Vs. Tort Fund, Tort Fund SPV1, Tort Fund SPV2, Michael Chhabra, Vineet Chhabra
WASHINGTON, Sept. 7 -- The Securities and Exchange Commission issued the following litigation release (No. 24-cv-02561; D.D.C. filed Sept. 6, 2024) involving Tort Fund LLC, Tort Fund SPV1 LLC, Tort Fund SPV2 LLC, Michael Chhabra and Vineet Chhabra:
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SEC Charges Litigation Financing Company and its Founders with Fraud
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The Securities and Exchange Commission charged Tort Fund, LLC and its founders, Florida residents Michael V. Chhabra and Vineet K. Chhabra, with the fraudulent offer and sale of at least $125,000 of securities to three investors between April 2019 and November 2019 and
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WASHINGTON, Sept. 7 -- The Securities and Exchange Commission issued the following litigation release (No. 24-cv-02561; D.D.C. filed Sept. 6, 2024) involving Tort Fund LLC, Tort Fund SPV1 LLC, Tort Fund SPV2 LLC, Michael Chhabra and Vineet Chhabra:
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SEC Charges Litigation Financing Company and its Founders with Fraud
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The Securities and Exchange Commission charged Tort Fund, LLC and its founders, Florida residents Michael V. Chhabra and Vineet K. Chhabra, with the fraudulent offer and sale of at least $125,000 of securities to three investors between April 2019 and November 2019 andthe misappropriation and misuse of the investors' money.
According to the SEC's complaint, the Chhabras falsely claimed that Tort Fund was actively lending money to law firms handling mass tort litigation on behalf of victims of allegedly defective medical devices or harmful consumer products. The Chhabras allegedly induced investments with Tort Fund and its related companies, Tort Fund SPV1, LLC and Tort Fund SPV2, LLC, by falsely claiming that investors would earn returns and interest or profits from the law firms' repayment of their high-interest debt instruments with Tort Fund. Contrary to their representations, Tort Fund and its related companies allegedly had not loaned any money to any law firm to fund mass tort litigation and had no agreements to do so. The complaint also alleges that the Chhabras misappropriated the money they raised to pay their own personal expenses and used the remainder to try to find new investors to perpetuate their fraudulent scheme.
The SEC's complaint, filed in federal court in the District of Columbia, charges Michael Chhabra, Vineet Chhabra, Tort Fund, Tort Fund SPV1 and Tort Fund SPV2 with violating Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. The SEC seeks permanent injunctions against all defendants and disgorgement, prejudgment interest, civil penalties and officer and director bars against Michael Chhabra and Vineet Chhabra.
The SEC's investigation was conducted by Patricia Trujillo and was supervised by Kingdon Kase, Scott A. Thompson, and Nicholas P. Grippo in the Philadelphia Regional Office. The litigation will be led by Kara F. Sweet and Judson T. Mihok and supervised by Gregory R. Bockin.
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Original text here: https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26098
Litigation: SEC Vs. Raskob Kambourian Financial Advisors
WASHINGTON, Sept. 7 -- The Securities and Exchange Commission issued the following litigation release (No. 4:24-cv-00442-MSA; D. Ariz. filed Sept. 5, 2024) involving Raskob Kambourian Financial Advisors Ltd.:
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SEC Charges Investment Adviser for Failing to Disclose Fee Increases to Clients
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On September 5, 2024, the Securities and Exchange Commission charged Raskob Kambourian Financial Advisors, Ltd. ("Raskob Kambourian"), a formerly SEC registered investment adviser based in Tucson, Arizona, with breaching its fiduciary duties by failing to disclose financial planning and investment
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WASHINGTON, Sept. 7 -- The Securities and Exchange Commission issued the following litigation release (No. 4:24-cv-00442-MSA; D. Ariz. filed Sept. 5, 2024) involving Raskob Kambourian Financial Advisors Ltd.:
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SEC Charges Investment Adviser for Failing to Disclose Fee Increases to Clients
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On September 5, 2024, the Securities and Exchange Commission charged Raskob Kambourian Financial Advisors, Ltd. ("Raskob Kambourian"), a formerly SEC registered investment adviser based in Tucson, Arizona, with breaching its fiduciary duties by failing to disclose financial planning and investmentmanagement fee increases to its clients.
According to the SEC's complaint, during the period of May 2019 through July 2022, Raskob Kambourian charged its clients fees that were higher than the amounts set forth in its clients' respective agreements. The SEC alleges that Raskob Kambourian periodically increased its fees, but, as a matter of general practice, did not expressly disclose those fee increases to clients, in breach of the firm's fiduciary duties. Additionally, according to the SEC's complaint, the SEC's "brochure rule" required Raskob Kambourian to disclose each fee increase as a "material change" to its Form ADV Part 2A (the "Brochure") that the firm filed with the SEC on an annual basis. The brochure rule further required Raskob Kambourian to deliver to each client, within 120 days of the end of the firm's fiscal year, its current Brochure, or, a summary of material changes to its Brochure with an offer to deliver the full Brochure. The SEC alleges that Raskob Kambourian failed to satisfy this requirement in each year from 2019-2022. According to the SEC's complaint, Raskob Kambourian charged approximately 59 clients a total of $1,364,513 more in fees than were authorized under the fee schedules set forth in its clients' respective agreements.
The SEC's complaint, filed in the U.S. District Court for the District of Arizona, charges Raskob Kambourian with violating Section 206(2) of the Investment Advisers Act of 1940 ("Advisers Act"), as well as the record-keeping, delivery, and compliance provisions of Sections 204(a) and 206(4) of the Advisers Act and Rules 204-2, 204-3, and 206(4)-7 thereunder. Without admitting or denying the allegations, Raskob Kambourian consented to the entry of a final judgment, subject to court approval, permanently enjoining it from future violations of the charged provisions; ordering Raskob Kambourian to pay disgorgement of $1,364,513 plus prejudgment interest thereon of $256,068; and imposing a civil money penalty of $225,000.
The SEC's investigation was conducted by Robert C. Stillwell and supervised by Finola H. Manvelian of the Los Angeles office. The litigation will be led by Daniel S. Lim and supervised by Douglas M. Miller. The SEC's examination that led to the investigation was conducted by Eric Lee and supervised by Andy Sohrn and Tamara Heller.
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Original text here: https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26097
FEC: Campaign May Engage in Joint Fundraising With Super PAC
WASHINGTON, Sept. 7 -- The Federal Election Commission issued the following advisory opinion document (No. AO 2024-07) on Sept. 6, 2024:
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A candidate's principal campaign committee may participate in a joint fundraiser with a Super PAC, so long as the committee and other entities affiliated with or acting on behalf of the candidate neither solicit, receive, direct, transfer or spend federally-impermissible funds nor engage in coordinated communications with the Super PAC.
Background
Team Graham, the principal campaign committee of Senator Lindsey Graham, currently participates in the Graham
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WASHINGTON, Sept. 7 -- The Federal Election Commission issued the following advisory opinion document (No. AO 2024-07) on Sept. 6, 2024:
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A candidate's principal campaign committee may participate in a joint fundraiser with a Super PAC, so long as the committee and other entities affiliated with or acting on behalf of the candidate neither solicit, receive, direct, transfer or spend federally-impermissible funds nor engage in coordinated communications with the Super PAC.
Background
Team Graham, the principal campaign committee of Senator Lindsey Graham, currently participates in the GrahamMajority Fund (Joint Fundraising Committee), a joint fundraising representative registered with the Commission. The other participating members of the Joint Fundraising Committee are Fund for America's Future, Graham's Leadership PAC, and the National Republican Senatorial Committee (NRSC).
Team Graham asks if it may amend the joint fundraising agreement to add a Super PAC as a participant. The expanded Joint Fundraising Committee will adhere to the applicable source prohibitions, contribution limits and the agreed upon allocation formula. Team Graham further states that although solicitations, invitations, and other fundraising related communications may be coordinated among the participating committees, the campaign will not discuss its nonpublic plans, projects, activities or needs with the Super PAC.
Analysis
The Commission concluded that Team Graham may amend the joint fundraising agreement to include a Super PAC as proposed for two reasons. First, neither Team Graham nor any other entity established, financed, maintained, or controlled by Senator Graham or acting on his behalf will solicit, receive, direct, transfer or spend funds that do not comply with the contribution limits, source prohibitions, and reporting requirements of the Federal Election Campaign Act. Second, neither Team Graham, Senator Graham, nor their agents will engage in coordinated communications with the Super PAC.
Date issued: August 29, 2024; Length: 9 pages
Citations
Regulations
11 C.F.R. Sec. 102.17
Joint fundraising by committees other than separate segregated funds
11 C.F.R. Sec. 109.21
What is a "coordinated communication"?
Statutes
52 USC Sec. 30125
Soft money of political parties
Resources
* AO 2024-07 (https://www.fec.gov/data/legal/advisory-opinions/2024-07/)
* Commission consideration of AO 2024-07 (https://www.fec.gov/updates/august-29-2024-open-meeting/)
Author
Christopher Berg, Communications Specialist
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Original text here: https://www.fec.gov/updates/ao-2024-07/
FCC Commissioner Carr Issues Statement on Review of Commission's Assessment, Collection of Regulatory Fees for FY 2024
WASHINGTON, Sept. 7 -- The Federal Communications Commission issued the following statement on Sept. 6, 2024, by Commissioner Brendan Carr on an action entitled "Review of the Commission's Assessment and Collection of Regulatory Fees for Fiscal Year 2024; Assessment and Collection of Space and Earth Station Regulatory Fees for Fiscal Year 2024, Second Report and Order."
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Congress requires the FCC and a number of other administrative agencies to fund their annual budgets by collecting fees every year from a portion of the businesses and licensees that we regulate or that benefit from the
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WASHINGTON, Sept. 7 -- The Federal Communications Commission issued the following statement on Sept. 6, 2024, by Commissioner Brendan Carr on an action entitled "Review of the Commission's Assessment and Collection of Regulatory Fees for Fiscal Year 2024; Assessment and Collection of Space and Earth Station Regulatory Fees for Fiscal Year 2024, Second Report and Order."
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Congress requires the FCC and a number of other administrative agencies to fund their annual budgets by collecting fees every year from a portion of the businesses and licensees that we regulate or that benefit from theFCC's work. Or to put it more precisely, the FCC collects these regulatory fees to offset the annual funding that Congress provides to the Commission through the appropriations process.
Despite this proceeding's staid title, "Review of the Commission's Assessment and Collection of Regulatory Fees," determining who pays and how much is the subject of regular tussling within the agency's docket. That makes sense. After all, millions of dollars are at issue, and this year Congress has directed the Commission to assess and collect $390 million for FY2024.
The FCC does not have an entirely free hand here, though. A lot of the agency's cuts are driven by determinations that Congress has made and codified in federal law. And the Commission is not going to make everyone happy. More often, regulated entities walk away with the feeling that they are being compelled to pay for the red tape that they will confront down the road.
Over the past several years, I have worked with my FCC colleagues to make progress on our approach to collecting and assessing regulatory fees. And I appreciate their efforts to accommodate many of my views. I will be voting to approve in part and dissent in part today.
Fundamentally, I believe the Commission can make even more progress in maximizing our efficiency as a government agency. And that starts with first principles thinking. Question every requirement. Delete unnecessary processes. Then simplify and optimize. If we start there first, then our regulatory fee process will align more closely with efficient outcomes. As it stands today, we're leaving too many cumbersome processes in place, putting lots of staff time into working through the issues and appeals and challenges that result from those processes, and then passing those staff time costs on to some businesses (but not others). That's not the most efficient approach or one that scales very well. I want to see the agency move more quickly in reforming our processes.
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Original text here: https://docs.fcc.gov/public/attachments/FCC-24-93A2.pdf
FCC Commissioner Carr Issues Statement on Inquiry Concerning Deployment of Advanced Telecommunications Capability
WASHINGTON, Sept. 7 -- The Federal Communications Commission issued the following statement on Sept. 6, 2024, by Commissioner Brendan Carr on an action entitled "Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, Eighteenth Section 706 Report Notice of Inquiry" (GN Docket No. 24-214).
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With this Notice of Inquiry, the FCC kicks off the process for completing next year's Section 706 Report, which seeks to answer whether broadband "is being deployed to all Americans in a reasonable and timely fashion."/1 While it is
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WASHINGTON, Sept. 7 -- The Federal Communications Commission issued the following statement on Sept. 6, 2024, by Commissioner Brendan Carr on an action entitled "Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, Eighteenth Section 706 Report Notice of Inquiry" (GN Docket No. 24-214).
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With this Notice of Inquiry, the FCC kicks off the process for completing next year's Section 706 Report, which seeks to answer whether broadband "is being deployed to all Americans in a reasonable and timely fashion."/1 While it isclear that my FCC colleagues and I would take different approaches to answering that question, I want to thank the Chairwoman for including three new lines of inquiry at my suggestion. As a result, I will be voting to approve in part and concur in part today.
First, the NOI now seeks comment on whether the FCC should report how many unserved locations are subject to enforceable federal commitments to deploy broadband infrastructure. Much of this data is available on a piecemeal basis today. Presenting it in an organized fashion could provide greater transparency to the public, ISPs, and other governmental agencies.
Understanding how many unserved locations are slated for future builds is more than good government, though. The information is badly needed. The Biden-Harris Administration has directed an unprecedented stream of taxpayer dollars to broadband deployment--chief among them the $42 billion BEAD program, which Vice President Harris was tasked to lead under the slogan of "Internet for All." As I have explained elsewhere, that $42 billion BEAD program has gone off the rails./2 More than 1,000 days since BEAD's enactment, not one home or business has been connected through that program. Nor has a single shovel's worth of dirt turned.
However troubling the Administration's failures may be, they are no longer surprising. The Administration has no strategy to coordinate the federal government's various broadband funding efforts that are now spread across 15 different agencies and more than 130 funding programs--something which the GAO warned in 2022 would be a recipe for and overbuilding wasteful duplication./3
Years later, one might have expected this Administration to have a plan to report how many unserved households have been, or will be, connected through funding programs spanning myriad agencies. Without that information, it is challenging to assess our efforts to close the digital divide. Yet, as far as I can tell, no such centralized resource publicly exists. So, by sizing up the interplay of unserved locations and enforceable commitments, the FCC can perform a valuable service and pick up for the Administration's slack.
Understanding our enforceable commitments can also help contextualize the Section 706 Report's conclusions. There is a temptation in some quarters to kick around the number of "unserved locations" as a political football, whether to justify more government spending or to rationalize new controls on the broadband industry. But the number of unserved locations, without more, does not tell the whole story. From a broadband funding perspective, an unserved location subject to an enforceable commitment is not the same as one without that commitment. Especially when many unserved locations will come online soon. As one example, the December 2024 deadline for 40% service under RDOF is approaching for many providers.
Nor does the mere existence of unserved locations end the FCC's inquiry and automatically result in a negative determination. The Communications Act does not require a simplistic, binary determination of whether advanced telecommunications capability has been deployed to all Americans. Rather, Section 706's language--particularly the statute's use of "reasonable and timely" and the present progressive tense "is being deployed"--confirms that Congress intended for the FCC to focus on the clip and cadence of ongoing deployment. Quantifying our enforceable commitments can inform that question.
Second, the NOI now tees up the concept of measuring progress by comparing results from the FCC's Broadband Data Collection. In past years, our Section 706 Reports relied on Form 477 data from trailing years. Following the Broadband DATA Act, the FCC now collects broadband deployment data every six months. And with a challenge process institutionalized, BDC datasets are more accurate than before. With four validated BDC maps under our belt and more to come, the FCC now has enough data to do an apples-to-apples comparison over time and understand how much progress has occurred on a biannual basis since 2022. Presenting these numbers side-by-side, with a particular focus on presenting the most recent BDC data, can shed more light on the rate of progress.
Third, I look forward to a more sophisticated discussion of high-speed satellite broadband services, such as those broadband services offered by constellations in low-Earth orbit. In Section 706 Reports predating the BDC, the FCC declined to treat satellite broadband as a true competitive option. That may have been understandable in years past when the technology was still nascent. But doubling down on that conclusion in 2024, as the last Section 706 Report did, makes little sense when thousands of satellites have since launched, with reported speeds exceeding 100/20 Mbps.
So, we are long overdue for a refresh on the competitive significance of satellite broadband. Indeed, each Section 706 Report should take a fresh look at emerging and extant sources of intermodal competition. That not only satisfies the Gretzky Test,/4 but the statute itself, which requires technological neutrality in the FCC's analysis of broadband deployment./5 I am therefore glad that the NOI asks about progress in satellite broadband, and I hope we approach that question thoughtfully.
To be sure, I still have overarching concerns with the way the FCC refashioned its Section 706 analysis in its last report./6 In the main, the FCC's novel framework is hardwired to reach a preordained determination that broadband is not being timely deployed to all Americans. We saw it when the FCC emphasized 100% availability instead of giving due weight to the rate of progress, as the statute requires. We saw it when the FCC evaluated extraneous factors--including "equitable access"--found nowhere in the statutory requirements for the Section 706 report. And we saw it in the new "long-term goal" of 1,000/500 Mbps that lays the groundwork to depart from the statute's mandate of technological neutrality.
Ultimately, while I still have concerns about the orientation of this Section 706 inquiry, I believe this NOI will help create a robust record. And I thank the Chairwoman once again for considering my feedback. Accordingly, I approve in part and concur in part.
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Footnotes:
1/ 47 U.S.C. Sec. 1302(b).
2/ See, e.g., Testimony of Brendan Carr, Commissioner, Federal Communications Commission, Before the Subcommittee on Communications Technology of the United States House of Representatives Committee on Energy and Commerce, The Fiscal Year 2025 Federal Communications Commission Agency Budget (July 9, 2024), https://d1dth6e84htgma.cloudfront.net/07_09_24_Testimony_Carr_8ee3f64be1.pdf; Testimony of Brendan Carr, Commissioner, Federal Communications Commission, Before the Subcommittee on Communications Technology of the United States House of Representatives Committee on Energy and Commerce, Connecting America: Oversight of the FCC (Mar. 31, 2022), https://docs.house.gov/meetings/IF/IF16/20220331/114545/HHRG-117IF16-Wstate-CarrB-20220331.pdf; Brendan Carr, Barreling toward a broadband blunder, The Hill (Apr. 8, 2021), https://thehill.com/blogs/congress-blog/technology/547073-barreling-towards-a-broadband-blunder.
3/ U.S. Government Accountability Office, Broadband: National Strategy Needed to Guide Federal Efforts to Reduce Digital Divide, GAO-22-104611 (May 31, 2022) (2022 GAO Report), https://www.gao.gov/assets/gao-22104611.pdf.
4/ See Address Of FCC Commissioner Brendan Carr at The Federalist Society 2019 National Lawyers Convention, The Future Of Telecommunications Law And Policy, Meeting The Gretzky Test (2019), https://docs.fcc.gov/public/attachments/DOC-360839A1.pdf ("And this brings me to The Great One, Wayne Gretzky, a Canadian by birth but an American at heart, who warned us against this status quo bias. The secret to his legendary success on the ice was to "skate to where the puck is going, not where it has been." The Gretzky Test is popular in sports and in business now, and I think competition authorities--and especially those of us in tech and telecom regulation--should hold ourselves to it, too.").
5/ Not just once, but twice, the statute expressly requires technological neutrality. See 47 U.S.C. Sec. 1302(d)(1) (defining "advanced telecommunications capability" as, "without regard to any transmission media or technology, as high-speed, switched, broadband telecommunications capability that enables users to originate and receive highquality voice, data, graphics, and video telecommunications using any technology") (emphases added).
6/ See Dissenting Statement of Commissioner Brendan Carr, Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, 2024 Section 706 Report (2024); Statement of Commissioner Brendan Carr, Approving in Part and Concurring in Part, Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, Notice of Inquiry (2023).
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Original text here: https://docs.fcc.gov/public/attachments/FCC-24-92A3.pdf
Court of Appeals Issues Opinion, Judgment in National Republican Senatorial Committee Vs. FEC
WASHINGTON, Sept. 7 -- The Federal Election Commission issued the following news release on Sept. 6, 2024:
The U.S. Court of Appeals for the Sixth Circuit issued an en banc Opinion and Judgment in National Republican Senatorial Committee, et al. v. FEC, et al. (Case Nos. 22-639/24-3051) yesterday, affirming that the limits on coordinated campaign expenditures of the Federal Election Campaign Act of 1971, as amended (the Act), do not violate the First Amendment.
Under the Act, a national party committee and state party committee may make expenditures in connection with the general election campaigns
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WASHINGTON, Sept. 7 -- The Federal Election Commission issued the following news release on Sept. 6, 2024:
The U.S. Court of Appeals for the Sixth Circuit issued an en banc Opinion and Judgment in National Republican Senatorial Committee, et al. v. FEC, et al. (Case Nos. 22-639/24-3051) yesterday, affirming that the limits on coordinated campaign expenditures of the Federal Election Campaign Act of 1971, as amended (the Act), do not violate the First Amendment.
Under the Act, a national party committee and state party committee may make expenditures in connection with the general election campaignsof federal candidates that are coordinated with those candidates.
These coordinated party expenditures do not count against the contribution limits but are subject to a separate set of limits. These limits are based on the office sought and the relevant voting-age population, and are adjusted annually for inflation.
Plaintiffs argued in their constitutional challenge that limiting the expenditures a party may make in coordination with its nominees unconstitutionally abridged the party's First Amendment rights.
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Original text here: https://www.fec.gov/updates/court-of-appeals-issues-opinion-and-judgment-in-national-republican-senatorial-committee-et-al-v-fec-et-al/
