Each year in the last couple weeks of September, the flow of SEC Litigation Releases announcing new cases filed by the Enforcement Division seems to turn from a slow but steady drip to a firehose blast. This year has been no exception, as the chart above indicates. By my quick count, after averaging just under 35 litigation releases per month for the first eight months of 2008, the SEC cranked out 66 litigation releases in September 2008, the most of any month this year.
Why is this? Is the SEC just tanned, rested and ready at the end of summer? Or maybe it’s that the staff finally has their kids back in school and now they can get back to business? No, the answer here lies in one of the key metrics the SEC is judged on by the media, Congress and others, as well as the calendar.
