Recent SEC Enforcement Developments -

.. Change in SEC policy regarding “no admissions” settlements

- SEC Chair Mary Jo White has joined with colleagues at DOJ to change the perception that U.S. companies are “too big to jail”

- SEC has made it a priority in “egregious” cases to require admissions of liability

..Recent settlements:

- SAC: agreed to plead guilty to insider trading violations and pay a $1.2 billion penalty

- JP Morgan: $200 million penalty in the London Whale case, coupled with JPM admissions of the facts underlying the SEC’s charges, and a public acknowledgement that JPM violated the federal securities laws