Until recently, those seeking to settle an action with the SEC were required to pursue two distinct tracks: resolution of a pending investigation negotiated with the SEC’s Division of Enforcement, and waiver of potential collateral consequences negotiated with the SEC’s Divisions of Corporate Finance and/or Investment Management (or SEC staff under delegated authority). The processes moved forward separately, could be time consuming and did not always follow the same timeline.
In light of the SEC’s recent announcement, that should now change.
‘Enforcement 40’ for 2020
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