On June 6th, the Northern District Court for California refused to retroactively apply Section 929M(2)(b) of the Dodd-Frank Act, which authorizes the SEC to sue for aiding and abetting a primary violation of the Investment Advisers Act. The SEC alleged defendants made misleading statements concerning the Charles Schwab YieldPlus Fund. Partially granting defendants' motion to dismiss, the Court held that nothing in the Dodd-Frank Act suggests that it was meant to apply retroactively. Since the events at issue occurred prior to the Act's enactment, the Court dismissed the charges based on Section 929M(2)(b). SEC v. Daifotis.