Whether the Valley lawyers’ message for SEC officials has any impact remains to be seen. At least one SEC watcher, however, expects the agency’s interest in transactions involving private companies to grow. Fenwick & West’s Michael Dicke, the former head of enforcement in the SEC’s San Francisco office, said after the event that he thinks that SEC officials will seize on the existence of the functioning secondary market for private company shares to take a closer look at the types of disclosures private companies are making to their employees and investors.
That, said Dicke, could be “a hook to more closely police private companies.”
‘Enforcement 40’ for 2020
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