So as Ms. White, Mr. Ceresney and Mr. Canellos begin their great journey together to enforce the securities laws, I congratulate them on their appointment and admire them for having the courage to take important jobs where, no matter what they do, they will be subjected to criticism. For it is a certainty that no matter what they do, some people will claim that they were too aggressive and others will claim that they were not aggressive enough. However, before they even start down their new path together, it is worth considering how to measure the success or failure of the SEC’s Division of Enforcement more generally. Here are some suggestions, in order of importance.
‘Enforcement 40’ for 2020
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