Last year, there were repeated calls for the SEC to reform its enforcement policies which, for the most part, went unheeded. The U.S. Senate Committee which held hearings on the botched Pequot hedge fund investigation made three key recommendations: 1) …

Part IV: SEC Enforcement Trends and Priorities 2008 – Calls For Reform Read More »

Three key enforcement policies concern corporate penalties, parallel proceedings and private actions. Each of these policies raises significant questions. The SEC has what can be viewed as a two-fold policy toward corporate penalties. One part is reflected in the policy …

Part III: SEC Enforcement Trends and Priorities 2008 – Policies (Cont) Read More »