Determining the Responsibilities of Underwriters Distributing Securities within an Integrated Disclosure System

13 This reasonable investigation and belief standard is discussed in the text accompanying notes 69-72 and in section III. A. infira.14 Exchange Act, § 18(a), 15 U.S.C. § 78r(a) (1976).15 Under § 11, the plaintiff need not show reliance on the statement or that the price at which he purchased the security was affected by the statement.Moreover, the defendant under § 18 need