In Morrison v. National Australia Bank Ltd., the Supreme Court limited the reach of Section 10(b) of the 1934 Securities Exchange Act to affect only those frauds in connection with "the purchase or sale of a security listed on an American stock exchange, and the purchase or sale of any other security in the United States." In response, Congress, in the Dodd-Frank Wall Street Reform and Consumer Protection Act, asked the Securities & Exchange Commission (SEC) to report on the extraterritoriality effects of the securities laws. In its study, the SEC offered several alternate approaches to the issue, including adopting the "conducts and effects test" that Morrison rejected or taking steps to "supplement and clarify" the "transactional test" adopted in Morrison.