SEC bar premised on pre-Dodd-Frank misconduct was applied in impermissibly retroactive way. The SEC brought a follow-on administrative proceeding against petitioner, who had been convicted of conspiracy, selling unregistered securities, and mail fraud. In that proceeding, the SEC permanently barred petitioner from associating with six classes of securities market participants. The DC Circuit granted petitioner’s challenge to the investment adviser, municipal securities dealer and transfer agent bar. While it agreed with the SEC’s findings and conclusions, it determined that the SEC applied that bar in an impermissibly retroactive manner as it was premised on pre-Dodd-Frank misconduct. (1/17/2017) Bartko v. Securities and Exchange Commission.