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Quotation from SEC v. Edwards by Supreme Court of the United States
“Moreover, investments pitched as low risk (such as those offering a "guaranteed" fixed return) are particularly attractive to individuals more vulnerable to investment fraud, including older and less sophisticated investors.”
SEC v. Edwards, Opinion of the Court (Justice O'Connor), Part II (U.S. Reports text (Legal Information Institute))

Justice O'Connor explains why excluding fixed-return schemes would undercut the securities laws' purposes.
Citation: "Moreover, investments pitched as low risk (such as those offering a "guaranteed" fixed return) are particularly attractive to individuals more vulnerable to investment fraud, including older and less sophisticated investors." — Supreme Court of the United States, SEC v. Edwards, Opinion of the Court (Justice O'Connor), Part II (U.S. Reports text (Legal Information Institute)). (id sec-v-edwards-q3)
Portrait: Sandra Day O'Connor crop, Library of Congress (Transferred by Sven Manguard,, Public domain.
