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SEC Reportedly Announces Major Reorganization of Enforcement and Exams Divisions

The U.S. Securities and Exchange Commission (SEC) has reportedly announced internally a major reorganization of its enforcement and exams divisions. This restructuring, effective April 9, 2025, was detailed in a staff memo...more

SEC 2024 Enforcement Results: A Decline in Total Enforcement, but a Record-Breaking Recovery of Financial Remedies

On November 22, the Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year (FY) 2024. As compared to FY 2023, the Division of Enforcement (the division) reported a 26% decline in the total...more

6 Considerations to Determine if a Cyber Incident Is Material

In late June, the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance released five new compliance and disclosure interpretations regarding the disclosure of material cybersecurity incidents...more

Cyber Incident Response Checklist for SEC Compliance

By now, public companies are generally aware of the cybersecurity rules adopted by the U.S. Securities and Exchange Commission a year ago, requiring public companies to disclose material cybersecurity incidents under Item...more

SEC Cybersecurity Incidents Disclosures: Materiality, Decryptors, and Ransom Payments - Dear Mary – Incidents + Investigations...

I work for a public company that recently experienced a ransomware attack. Fortunately, we were able to restore our business operations quickly by obtaining a decryption key from the threat actor. Given that we managed to get...more

SEC Charges Broker-Dealer and Two Affiliated Investment Advisers With Violating Whistleblower Protection Rule

On September 4, the Securities and Exchange Commission (SEC) issued an order against three investment adviser firms for violating the whistleblower protections of Rule 21F-17(a) under the Securities Exchange Act of 1934. This...more

SEC Charges Investment Advisor for Misleading Disclosures About Its Work With Short Publishers

On June 11, the Securities and Exchange Commission (SEC) announced the first settled case in its ongoing review of collaborations between investment advisors and short publishers. The SEC fined affiliated investment advisors...more

Unanimous Supreme Court Decision Allows for Early Challenges to Federal Agency Enforcement Actions

On April 14, the Supreme Court unanimously held that federal district courts have jurisdiction to review constitutional challenges to the structures of the Federal Trade Commission (FTC) and Securities and Exchange Commission...more

SEC Settlement With McDonald's and Ex-CEO Signals Potential Expansion of Executive Compensation Disclosure Requirements

On January 9, the Securities and Exchange Commission (SEC) announced that it had reached a settlement with McDonald’s and its former CEO, Stephen Easterbrook, for charges stemming from McDonald’s 2019 termination of...more

FINRA Issues 2023 Examination and Risk Management Program Report: What It Says and How to Respond

On January 10, FINRA published its “2023 Report on FINRA’s Examination and Risk Management Program” (Report) — FINRA’s third annual compendium of guidance, covering key topics and emerging risks for member firms to consider...more

SEC's Enforcement Results for FY 2022 Reflect Robust Enforcement and Record-Breaking Penalties

On November 15, the U.S. Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year 2022, which featured the following key metrics...more

SEC Modernizes Its Recordkeeping Requirements for Certain Registrants

On October 12, the Securities and Exchange Commission (SEC) voted to adopt new electronic recordkeeping requirements for broker-dealers, security-based swap dealers (SBSDs), and major security-based swap participants (MSBSPs)...more

SEC Targets SPAC Conflicts of Interest

On September 6, investment advisory firm Perceptive Advisors LLC (Perceptive) agreed to a cease-and-desist order with the U.S. Securities and Exchange Commission (SEC) for failing to disclose alleged conflicts of interest...more

SEC Cracks Down on Encrypted Messaging

While the phrase “clandestine messaging” evokes secret notes slipped under doors and written in code, its meaning in the world of securities regulation and enforcement is not nearly as romantic as the name suggests....more

FINRA Report Highlights New Topics and Emerging Risks for 2022

On February 9, FINRA published its 2022 Report on FINRA’s Examination and Risk Management Program (2022 Report), an authoritative resource for member firms to evaluate and, where necessary, enhance their compliance programs...more

President Biden’s Working Group on Financial Markets Issues Report on Stablecoins

On November 1, the President’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, issued a “Report on Stablecoins” (Report) that...more

President Biden's Working Group on Financial Markets Issues Report on Stablecoins

On November 1, the President’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, issued a “Report on Stablecoins” (Report) that...more

Gensler's SEC Agenda: Commitment to ESG and Increased Disclosures

On June 11, the Biden administration’s Office of Information and Regulatory Affairs (OIRA) released the Securities and Exchange Commission’s (SEC or Commission) rulemaking agenda (Rulemaking Agenda) as part of the Spring 2021...more

Congress Passes Law Expanding the SEC's Ability to Seek Disgorgement

On Friday January 1, with the Senate’s floor vote to override the president’s veto, Congress passed the 60th annual National Defense Authorization Act (NDAA). Encompassed within the $740.5 billion military spending bill is an...more

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