In Morrison, the Supreme Court held that Section 10(b) of the Exchange Act applies only to “transactions in securities listed on domestic [U.S.] exchanges, and domestic [U.S.] transactions in other securities.” The Dodd-Frank Act effected a complete legislative repeal of Morrison for SEC actions, but also required the SEC to study whether the repeal should be extended to private actions. Alex Lakatos argues that such an extension would be a bad idea.

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