Only three of the agency’s five commissioners voted on [JPMorgan] settlement, which included an acknowledgement of wrongdoing by the bank. SEC Chairman Mary Jo White and Republican Commissioner Daniel Gallagher were recused from the case given legal work their previous employers – Debevoise & Plimpton LLC and Wilmer Cutler Pickering Hale and Dorr LLP — had done for J.P. Morgan.
The settlement itself was the product of an investigation by just one of the SEC’s top enforcement cops, with the agency’s co-director of enforcement, Andrew Ceresney, also recused because of his work at Debevoise.
‘Enforcement 40’ for 2020
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