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Factors to be considered to arrive at the settlement terms
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....including but not limited to the following: (a) conduct of the applicant in the investigation; (b) the role played by the applicant in case the alleged default is committed by a group of persons; (c) nature, gravity and impact of alleged defaults; (d) whether any other proceeding against the applicant for non-compliance of securities laws is pending or concluded....
TaxTMI