The way work flows from the regional offices to the commission could also be a reason most regional directors come from the enforcement side. Jerry Hodgkins, a Covington & Burling partner and former associate director for the SEC’s enforcement division, said regional office enforcement staff can get almost weekly interaction with the commission.
“Enforcement actions that are recommended by the staff have to be approved by the commission, and so they have to go directly to the commission for every single action, and that could be as many as 500 a year,” Hodgkins said.
“About 90% of the commission’s meetings are related to the enforcement program, so I think the reality is that when the commission is doing its business, a lot of it is enforcement work,” he said. “So when they’re thinking of promoting a regional director, they probably are looking for somebody who they can rely on to run an enforcement program and present those cases effectively to the commission.”
‘Enforcement 40’ for 2020
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