The Securities and Exchange Commission had charged two retail brokers with making false and misleading statements and with omissions of material fact in connection with the sale of securities to municipalities. Many of the charges involved inadequate or misleading disclosures of risk.

A NERA expert testified on behalf of the brokers, describing the relevant risks and then showing how they had been presented to the customers.

In a detailed decision, the administrative law judge used the evidence of the actual disclosures to find in favor of the brokers.