In a recent speech before the Compliance and Legal Society of the Securities Industry and Financial Markets Association, Robert Khuzami—director of the Securities and Exchange Commission (SEC) Division of Enforcement—ran through a list of notable enforcement efforts over the past year or so. The audience, comprised as it was of securities industry practitioners and professionals, was keenly aware of what the SEC had done, and had failed to do, over the past number of years. We all listened politely and gave Khuzami the respect that he had earned as a successful prosecutor and now the chief securities law enforcement officer in the country.
Most of what Khuzami reported was familiar and expected. One item that he mentioned, however, definitely caught my attention. The reference, like my attention span, was brief. The potential impact, however, is not.
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