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Accounting Firms Face Increased Exposure to Securities Fraud Claims after Supreme Court Declines to Take Appeal

On October 6, 2025, the U.S. Supreme Court denied a petition for certiorari in BDO USA,LLP v. New England Carpenters Guaranteed Annuity and Pension Funds, No. 24-1151, a closely watched case involving securities fraud claims...more

Second Circuit Opinion Highlights Need for Public Companies to Revisit Risk Disclosures

On August 27, 2025, the U.S. Court of Appeals for the Second Circuit issued an opinion highlighting that, when public companies disclose risks using hypothetical language, those disclosures may be deemed misleading if the...more

SEC Charges Public Company and Executive with Disclosure Fraud

On September 5, 2025, the U.S. Securities and Exchange Commission (SEC) brought enforcement actions against a public company and one of its executives for materially misleading statements. Although disclosure fraud cases are...more

SEC Targets Broker-Dealers for Reg BI Violations

On August 11, 2025, the U.S. Securities and Exchange Commission (SEC) brought two settled administrative proceedings against a broker-dealer and one of its registered representatives for violations of Regulation Best Interest...more

SEC Enforcement in the Second Quarter of 2025

In May 2025, we summarized the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement activity during the first quarter of the new presidential administration. With the second quarter now concluded, and Paul...more

SEC Disgorgement Stuck in Circuit Split After Supreme Court Declines to Intervene

On June 6, 2025, the U.S. Supreme Court denied a petition for certiorari in Navellier & Associates, Inc. v. SEC, declining to resolve a circuit split regarding the circumstances under which the U.S. Securities and Exchange...more

SEC Continues to Scrutinize Investment Adviser Fee Disclosures

Although certain enforcement priorities of the U.S. Securities and Exchange Commission (SEC) have shifted under new Chairman Paul S. Atkins, the SEC continues to scrutinize investment advisers’ disclosures regarding the fees...more

SEC Enforcement Leadership Discusses New Priorities and Expectations

On May 20, 2025, as part of the annual “SEC Speaks” program, the leadership of the U.S. Securities and Exchange Commission’s (SEC) Division of Enforcement publicly discussed the enforcement priorities under new Chairman Paul...more

SEC Enforcement in the First Quarter of the New Administration

The new presidential administration began on January 20, 2025, and change came quickly to many federal agencies, including the U.S. Securities and Exchange Commission (SEC). On Inauguration Day, Paul S. Atkins was nominated...more

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