following: 4F. Certain findings required to approve civil money penalties against issuers The Commission may not seek against or impose on an issuer a civil money penalty for violation of the securities laws unless the publicly available text of the order approving the seeking or imposition of such penalty contains findings, supported by an analysis by the Division of Economic and Risk Analysis and certified by the Chief Economist, of whether— (1) the alleged violation resulted in direct economic benefit to the issuer