It’s the primary axiom of corporate compliance: A new rule emerges over the horizon, companies ignore it until the rule’s arrival is imminent, and then they panic and scramble to implement a compliance regime as quickly as possible. The Securities and Exchange Commission seems to be following a similar pattern.
Stronger enforcement is now the order of the day at the SEC. After years of soft-pedaling enforcement under the Bush Administration, the agency has gone into overdrive with all manner of new plans, new funding, and new promises to crackdown on offenses. For an overview of what’s coming, I’d suggest reading the column by our legal writer, Bruce Carton, on pages 20-21; he has some excellent commentary from sources inside the SEC Enforcement Division.
