On Tuesday, the SEC announced that it had filed a complaint in the Southern District of New York charging Bank of America with violating the federal proxy rules by failing to disclose extraordinary financial losses at Merrill Lynch prior to a BofA shareholder vote to approve a merger between the two companies. The SEC had previously announced that it had submitted a motion seeking to amend its existing complaint in the currently pending matter before the U.S. District Court for the Southern District of New York to include the new charges. On Monday, that motion was denied by U.S. District Judge Jed Rakoff.