Whether the SEC properly construed and applied federal venue laws

QUESTIONS PRESENTED This petition for Writ of Certiorari involves a civil enforcement complaint filed by the Securities and Exchange Commission against the globally situated Stanford Financial Group of financial services companies (wholly owned by R. Allen Stanford), a Temporary Restraining Order (TRO), and the court-appointment of an Equity Receiver who would take exclusive control of this global group of companies and all of its assets, as well as those of R. Allen Stanford, both personal and corporate; and a related ‘ancillary’ proceeding filed against HSBC Bank, Toronto Dominion Bank, and Independent Bank of Houston; collectively referred to as the "Bank Defendants". The questions presented concern the statutory construction, interpretation and application of the federal venue laws, and the boundaries of a United States District Court as authorized by Article III of the U.S. Constitution, and codified in statute by the United States Congress; the "place where a corporation is fairly regarded as at home" and has its "principle place of business", establishing the "paradigm forum for general jurisdiction"; and the ‘ultra vires’ divestiture of a District Court's original exclusive jurisdiction; substantive issues that were first raised in the ‘main action’ case, and then here, in this ‘ancillary’ "Final Judgment and Bar Order" proceeding (involving a "Bank Defendant Settlement Agreement", in the "Rostain/Trustmark Litigation" in the amount of $1.345 billion), in both the District Court and the Court below. The questions presented, which are compound in nature, are: (1) Whether, when filing a civil enforcement complaint (in the Northern District of Texas, Dallas Division) against a global financial services company (headquartered in the 2 Southern District of Texas, Houston Division) alleging violations of the federal securities laws, the United States Securities and Exchange Commission constructed, interpreted and applied the federal venue laws (28 U.S.C. 1391(b) and Fed. R. Civ. P. 66) in a sweeping and never-asserted manner that afforded itself "statutory under Chevron USA Inc. v. Natural Resources Defense Council, 467 U.S. 837 (1984); therein allowing that agency to disregard both the and mandates in the federal venue laws, as well as the corollary "principle place of business" paradigm forum for "general jurisdiction" as clearly articulated by the U.S. Supreme Court in Daimler AG v. Bauman, 571 U.S. 117,127 (2014), and; (2) Whether, upon appointment by the District Court for the Northern District of Texas, Dallas Division, and mandated by an Order Appointing Receiver to establish and operate his "principle place of business" there in, the Northern District of Texas, the Equity Receiver acted in an ‘ultra vires' manner when instead he promptly relocated the receivership to, and reported to the Court in his first Report of the Receiver, that he and his "team of professionals" had established their extensive operations and administrative activities within the North American headquarters of the Stanford Financial Group, situated in the Southern District of Texas, Houston Division; which was outside the District Court's boundaries, and thus the appointing District Court's "host district" congressional authority, to 'supervise' the administrative activities of its appointed Equity Receiver; and in so doing, whether that record-supported ‘ultra vires’ action served to "divest" the appointing District Court of its original, exclusive jurisdiction, and; (3) Whether, when a timely challenge was made to the SEC's choice of venue, in the form of a ‘Responsive Answer’, as clearly permitted by Fed. R. Civ. P. 12(h)(1), (a) the District Court abused its discretion when it then arbitrarily held that the venue challenge had been 'waived and forfeited by the failure to raise it in a first ‘Motion 3 to Dismiss', under Fed. R. Civ. P. 12(b); and (b) whether, when raised in the instant ancillary 'Final Judgment and Bar Order' appellate