Securities and Exchange Commission Division of Enforcement, Enforcement Manual, Office of Chief Counsel, October 6, 2008: “The Enforcement Manual (“Manual”) is an electronic document designed to be a reference for the staff in the U.S. Securities and Exchange Commission’s (“SEC”) Division of Enforcement (“Division” or “Enforcement”) in the investigation of potential violations of the federal securities laws. It contains various general policies and procedures and is intended to provide guidance only to the staff of the Division. It is not intended to, does not, and may not be relied upon to create any rights, substantive or procedural, enforceable at law by any party in any matter civil or criminal.”