8.8. Play #97: When It Comes to Compliance, Always Play by the Rules

In the final weeks before the IPO, Steve Cakebread, the I-banking team, and I had scheduled trips to major finance centers in Europe and the United States to visit the top institutional money managers and other investors and give them our thirty-minute pitch. We were at the start of the road show and had just arrived in Washington, DC, when we got a disturbing phone call from one of our advisers: "There's a problem; the IPO is being held up."

As the shock subsided and the weight of that statement set in, we learned that the SEC believed that we had violated securities law by promoting our offering before the regulators had declared it ready to go. This accusation referred to ...

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