Section 17(a) of the exchange act and rule 17a-4(b)(4) July 8, 2019 16 32 64 128 Section 17 a of the exchange act and rule 17a 4 b )( 4 Section 17(a) of the exchange act Section 17(a) of the exchange act and rule 17a-4 Section 17(a) of the securities exchange act of 1934 Exchange act rule 17a-3 17(a) exchange act