In re Stanford Management Corp.
CFTC Docket No. 83-18
Matter at a glance
- Year
- 1983
- Agency
- Commodity Futures Trading Commission
- Forum
- Administrative proceeding
- Mr. Lehrer's role
- Principal investigator
- Docket / file
- CFTC Docket No. 83-18
What the matter involved
Fraud and churning by a commodity pool operator.
The matter was brought by the Commodity Futures Trading Commission and heard as a administrative proceeding. Mr. Lehrer worked the file as a principal investigator, which meant building the record on the government's side — the documents, the testimony, and the theory of the violation — rather than responding to it.
- Commodity pool. Commodity pool was one of the issues at the centre of this matter and remains a recurring theme in agency enforcement.
- Churning. Churning was one of the issues at the centre of this matter and remains a recurring theme in agency enforcement.
Outcome and public record
This matter was resolved on the public record of the Commodity Futures Trading Commission under CFTC Docket No. 83-18. Out of respect for the individuals and entities named, this page does not restate penalties, bars, or sentences. The agency's own release for the matter is the authoritative record of its disposition.
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Past results in government enforcement matters do not predict or guarantee the result of any future matter. This page describes work performed on behalf of a government agency before Mr. Lehrer entered private practice in 2000.
Why this matters to issuers today
The staff still builds files the same way: start with the public document, test it against the company's own records, and interview the people who signed. Knowing how that record gets assembled is the reason issuers bring this experience in at the drafting stage — before a filing, an offering, or a promotion creates the paper trail a later investigation would follow.
Questions about a filing, an offering, or a promotion?
Talk directly to a former SEC enforcement attorney — no intake staff, no forms.