To read the full version of this content please select one of the options below:

SEC releases enforcement division FY 2017 annual report: shift in tone and likely approach

Matthew C. Solomon (Cleary Gottlieb Steen and Hamilton LLP, Washington, DC, USA)
Robin M. Bergen (Cleary Gottlieb Steen and Hamilton LLP, Washington, DC, USA)
Alexis Collins (Cleary Gottlieb Steen and Hamilton LLP, Washington, DC, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 8 May 2018

Abstract

Purpose

To discuss and analyze the US Securities and Exchange Commission’s (SEC’s) FY 2017 Annual Report, which details its priorities for the coming year and evaluates enforcement actions that occurred during FY2017.

Design/methodology/approach

Summarizes key shifts from FY 2016, outlines the Enforcement Division’s current priorities, and, in view of its stated focus on the conduct of investment professionals and protection of retail investors, provides guidance to the investment management industry as it gears up for the coming year.

Findings

The Report provides insight into changes in the SEC’s approach to enforcement actions, including a general shift in tone suggesting a more measured approach to enforcement and remedies and a move away from a statistics-oriented approach, and a glimpse into its priorities for the coming year, including five core principles guiding the Division’s enforcement decisions.

Practical implications

As those in the asset management industry consider revisions to their policies and procedures for FY 2018, as well as their risk profile more generally, they should keep in mind key insights into the Commission’s enforcement strategy offered by the Report.

Originality/value

Practical guidance from experienced securities enforcement, litigation, compliance and anti-corruption lawyers.

Keywords

Citation

Solomon, M.C., Bergen, R.M. and Collins, A. (2018), "SEC releases enforcement division FY 2017 annual report: shift in tone and likely approach", Journal of Investment Compliance, Vol. 19 No. 1, pp. 15-19. https://doi.org/10.1108/JOIC-02-2018-0015

Publisher

:

Emerald Publishing Limited

Copyright © 2018, Cleary Gottleib Steen & Hamilton.