Law360, New York ( March 2, 2012, 1:23 PM EST) -- On Oct. 19, 2009, the U.S. Securities and Exchange Commission instituted an administrative proceeding against Theodore Urban, the former general counsel of a broker-dealer, alleging that he had "failed to supervise" a registered representative of the firm. Urban was alleged to have been alerted to possible wrongdoing by a registered representative of the firm, to have tried to investigate and to stop any misconduct, but to have done too little to stop this misconduct. On first glance, it is difficult to identify a theory of liability under which Urban could be charged. He did not commit illegal acts, did not aid and abet or cause others to commit illegal acts, and was not the line supervisor of any wrongdoer....