Implications of the New SEC Penalty Policy

This post is by Theodore Mirvis of Wachtell, Lipton, Rosen & Katz.

SEC Chairman Christopher Cox recently announced a new protocol for the negotiation of a monetary settlement by the agency’s enforcement staff.  In a pilot test, the staff will be required to get a green light from the Commission before starting to negotiate.  There is some uncertainty, to say the least, about how this will work, as this memo points out, including as to the established Wells process.

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