Recent pronouncements made by the U.S. Securities and Exchange Commission (SEC) leadership, alongside the recent overhaul of the SEC Enforcement Manual, collectively signal a back-to-basics enforcement approach that appears beneficial for companies in their dealings with the agency.
A back-to-basics enforcement approach does not mean a lax enforcement approach, however. “[R]eports that enforcement work at the SEC has been tossed to the wayside are not only greatly exaggerated, but flat out wrong,” SEC Enforcement Division Director Margaret Ryan said in remarks at the Los Angeles County Bar Association in February.
