Trends in SEC Enforcement – 4Q23: Part IV, Conclusion
This is the concluding segment of a four part series analyzing trends in SEC Enforcement during 2023. Part I of this series focused on the number of cases filed during the quarter and the largest categories of cases. Part II provided examples of the types of cases included in each of the largest groups of actions initiated during the period. Part III provided examples of significant actions filed in the fourth quarter that were not included in the largest groups of actions.
The fourth quarter of 2023 was representative in many ways of the entire year. During that period the fewest enforcement actions were initiated for any quarter of the year. Yet the numbers for each quarter are consistent with the “up and down” trend of the year. In the first quarter of the year, for example, 80 new enforcement actions were filed. That number dropped to 46 for the second quarter while it jumped to 144 in the third, traditionally the time the Commission pushes to file new cases since it is the end of the Government fiscal year, and then declined to 43 for the final period of 2023.
Ending the year on a low point in terms of the number of cases filed also seems consistent with the overall trend of 2023. During 2023 the Enforcement program initiated only slightly more than 300 enforcement actions. This is fewer that in earlier years as reflected in earlier articles.
Similarly, the number of categories in which cases were filed during 2023 declined slightly during the year. In 2023 actions were filed in 19 different categories. During the prior year, in contrast, cases were filed in nearly 25 different areas. Overall, the statistics for 2023 reflect a program that was less productive in terms of numbers than during earlier periods.
It is important to note, however, that the numbers are at most one measure of the program, a point that has been reiterated here many times over the years as trends in SEC enforcement have been analyzed. There is no doubt, for example, that the Commission filed a wide range of actions in 2023 as reflected in the numerous cases included in this series demonstrates. even if the number of areas in which they were brought declined slightly. As those examples illustrate, the cases filed involved a wide variety of areas ranging from the foreign corrupt practices act to insider trading, municipal bonds and maintaining the appropriate books and records. Filing such a wide variety of cases puts the markets and its participants on notice that the Commission is carefully monitoring them to protect the integrity of each transaction and the overall markets as well as each person involved with the transactions. While the number of cases filed last year may not be as large as in prior periods, there should be no doubt that the Commission and its staff continually study and monitor the markets for the benefit of all.
Trends in SEC Enforcement – 4Q23: Part IV, Conclusion
This is the concluding segment of a four part series analyzing trends in SEC Enforcement during 2023. Part I of this series focused on the number of cases filed during the quarter and the largest categories of cases. Part II provided examples of the types of cases included in each of the largest groups of actions initiated during the period. Part III provided examples of significant actions filed in the fourth quarter that were not included in the largest groups of actions.
The fourth quarter of 2023 was representative in many ways of the entire year. During that period the fewest enforcement actions were initiated for any quarter of the year. Yet the numbers for each quarter are consistent with the “up and down” trend of the year. In the first quarter of the year, for example, 80 new enforcement actions were filed. That number dropped to 46 for the second quarter while it jumped to 144 in the third, traditionally the time the Commission pushes to file new cases since it is the end of the Government fiscal year, and then declined to 43 for the final period of 2023.
Ending the year on a low point in terms of the number of cases filed also seems consistent with the overall trend of 2023. During 2023 the Enforcement program initiated only slightly more than 300 enforcement actions. This is fewer that in earlier years as reflected in earlier articles.
Similarly, the number of categories in which cases were filed during 2023 declined slightly during the year. In 2023 actions were filed in 19 different categories. During the prior year, in contrast, cases were filed in nearly 25 different areas. Overall, the statistics for 2023 reflect a program that was less productive in terms of numbers than during earlier periods.
It is important to note, however, that the numbers are at most one measure of the program, a point that has been reiterated here many times over the years as trends in SEC enforcement have been analyzed. There is no doubt, for example, that the Commission filed a wide range of actions in 2023 as reflected in the numerous cases included in this series demonstrates. even if the number of areas in which they were brought declined slightly. As those examples illustrate, the cases filed involved a wide variety of areas ranging from the foreign corrupt practices act to insider trading, municipal bonds and maintaining the appropriate books and records. Filing such a wide variety of cases puts the markets and its participants on notice that the Commission is carefully monitoring them to protect the integrity of each transaction and the overall markets as well as each person involved with the transactions. While the number of cases filed last year may not be as large as in prior periods, there should be no doubt that the Commission and its staff continually study and monitor the markets for the benefit of all.