Remarks at SEC Speaks 2024 — Sanjay Wadhwa

Since December 2021, the Commission has charged nearly 60 firms – investment advisers, broker-dealers, and credit ratings agencies – with recordkeeping violations, resulting in combined penalties of just over $1.7 billion. This initiative has received a great deal of attention, much of it focused on penalties, which were as high as $125 million for some of the firms, while, on the lower end of the spectrum, one firm paid a $2.5 million penalty.

Perhaps as a result of that wide range in penalties, there has been a critique from the defense bar that we’re picking numbers at random; that they’re not informed by individualized determinations. I’m here to disabuse you all of that perception: stated simply, we do make an individualized assessment of each firm. I’ll share some of the factors we focus on….

Source: Remarks at SEC Speaks 2024 — Sanjay Wadhwa