Final disgorgement order cannot be collaterally challenged; recovery notice including interest was upheld.

A collateral challenge to a recovery notice implementing a final disgorgement direction was not maintainable after the underlying order had already been unsuccessfully challenged and reviewed. The notice correctly enforced the earlier disgorgement order, including interest accruing from default in payment within the stipulated period, because the original direction had attained finality. The recovery action was therefore upheld and the appeal failed.

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Issues: Whether the recovery notice demanding disgorgement with interest from the date of the original order could be assailed in collateral proceedings after the underlying disgorgement order had attained finality.

Analysis: The underlying order directing disgorgement had already been challenged and the challenge, as well as the review, had failed. The recovery notice merely implemented that final direction, including the consequence of interest upon default within the stipulated period. A collateral challenge to such consequential recovery action was not maintainable once the original order had attained finality.

Conclusion: The recovery notice was upheld and the appeal was dismissed.

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