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The Securities Act of 19331 and the Securities Exchange Act of 19342 give the investor various expansive civil remedies against deceitful securities underwriters, 3 offerors and sellers.4 Armed with these broad causes of action, private investors would appear to be wellprotected against the fraudulent acts of securities salesmen. In many situations, however, an action against the wrongdoing salesman may be fruitless. Since salesmen usually have only limited financial resources, the injured investor will generally prefer to sue the party with the "deepest pockets," the party most able to bear the loss. Moreover, when named as defendants in a securities fraud suit, salesmen often find it convenient to disappear, leaving the plaintiff with, at most, an unsatisfied default judgment.5 Thus, the defrauded investor almost

The "Controlling Persons" Liability of Broker-Dealers for Their Employees' Federal Securities Violations