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CHATHAM v. SECURITIES & EXCH. COM'N

No. 76-1724.

604 F.2d 1368 (1978)

Richard Lee CHATHAM, Petitioner, v. SECURITIES AND EXCHANGE COMMISSION, Respondent.

United States Court of Appeals, District of Columbia Circuit.

Decided November 9, 1978.

Attorney(s) appearing for the Case

Norman S. Johnson and Paul T. Moxley, Salt Lake City, Utah, were on the brief for petitioners.

David Ferber, Sol., Kathryn B. McGrath, Asst. General Counsel, and Frank A. Wilson, Atty., S. E. C., Washington, D. C., were on the brief for respondent.

Before LEVENTHAL and ROBINSON, Circuit Judges, and RICHEY, United States District Judge for the District Court of the District of Columbia.

Opinion PER CURIAM.

PER CURIAM:

Petitioner contests the factual basis for the Commission's order1 finding that he had willfully aided and abetted violations of (a) the "net capital" rule — which requires a broker-dealer to maintain sufficient liquid assets to protect its customers2 — (b) the requirement that proceeds of a public offering be promptly placed in an escrow account

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