SEC Enforcement in 2009: A Year of Changes, with More This Year

by Eduardo Gallardo, for The Harvard Law School Forum at Harvard Law School, February 1, 2010.

In our 2009 “Mid-Year Review of SEC Enforcement,” we reviewed the transformation that had begun in 2009 at the SEC’s Division of Enforcement under the agency’s new Chairman, Mary Schapiro, and the Division’s new Director, Robert Khuzami, as well as the measurable increase in enforcement activity that had resulted. Since then, Mr. Khuzami has articulated more specifically the changes the he plans to make, some of which are already in effect and others that have yet to be implemented. Nevertheless, the results of the Enforcement Division continue to reflect the heightened enforcement initiative that has been the calling card of this Commission. In this review of enforcement in 2009, we focus on the significant enforcement developments of the second half of the year, as well as notable cases and important trends revealed by annual enforcement statistics, both those disclosed by the SEC, as well as those that result from our own analysis. We also look ahead to the significant developments to anticipate this year.

I. Overview of 2009’s Second Half

A. Enforcement Director’s New Initiatives

In a speech delivered in August marking his first 100 days as Division Director, Mr. Khuzami outlined five new initiatives to reorganize the Enforcement Division and modify the process for investigations. While some of the changes became effective immediately, the more significant programmatic changes still await full implementation. For a more detailed description of Mr. Khuzami’s speech, see our alert, “SEC’s Enforcement Director Robert Khuzami Emphasizes Changes and Accomplishments in First 100 Days“…(continue reading)


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