In the Matter of Howe, Solomon and Hall
Admin. Proc. File No. 3-9613 (May 28, 1998)
Matter at a glance
- Year
- 1998
- Agency
- U.S. Securities and Exchange Commission
- Forum
- Administrative proceeding
- Mr. Lehrer's role
- Principal litigator
- Docket / file
- Admin. Proc. File No. 3-9613 (May 28, 1998)
What the matter involved
Excessive markups on municipal bond sales.
The matter was brought by the U.S. Securities and Exchange Commission and heard as a administrative proceeding. Mr. Lehrer worked the file as a principal litigator, 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.
- Municipal securities. Municipal transactions carry their own rulebook, and markup practices are measured against the prevailing market price at the time of the trade.
- Excessive markups. Markup cases are arithmetic first: the price charged to the customer against the dealer's contemporaneous cost.
Outcome and public record
This matter was resolved on the public record of the U.S. Securities and Exchange Commission under Admin. Proc. File No. 3-9613 (May 28, 1998). 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.