United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT Argued September 24, 2020 Decided November 6, 2020 No. 19-1214 John M.E. Saad, Petitioner v. Securities and Exchange Commission, Respondent On Petition for Review of an Order of the Securities and Exchange Commission Sarah Levine argued the cause for petitioner. With her on the briefs was Alex Potapov. Dina B. Mishra, Senior Counsel, Securities and Exchange Commission, argued the cause for respondent. With her on the brief was John IV. Avery, Deputy Solicitor. Michael A.