If these reports are accurate, however, what lessons may be drawn from the change? Initial reactions have largely focused on whether centralizing formal order authority with the Acting Division Director reflects an effort to slow the pace of SEC investigations. But this assertion seems incomplete at best, and may largely miss what is really going on. It’s hard to draw definitive conclusions from a non-public action of an Acting Chair without the input of the Commission’s full five-member complement; but we believe the reasons underpinning this reported interim effort are more nuanced than a simple desire to roll back enforcement….
