Perhaps the biggest dirty little secret has been the practice of salting the landscape with Analytical Shills. These are people who pose as independent analysts, but are underwritten by the crafty market manipulators. In 2003, Ten of Nation's Top Investment Firms settled an SEC Enforcement Action involving obvious Conflicts of Interest Between Research and Investment Banking. Naturally the SEC did more to cover up the practice than anything else. The firms paid ONLY a penalty of $487.5 million, Disgorgement of $387.5 million, payments of $432.5 million to Fund Independent Research, and Payments of $80 million to Fund Investor Education. The firms never had to admit to anything and private suits were dismissed by Judge Pollack in New York saying the investors should have known they were taking risk.