Industry Blogs and Articles

SEC Enforcement Division Revises Its Playbook: What the Updated Manual Signals About Enforcement Practices and Defense Strategy

The SEC Enforcement Division has updated its manual to require two‑level, director‑level approval before a Wells notice can be issued. This formalizes a practice that previously existed informally, potentially creating a bureaucratic bottleneck that slows investigations toward charging decisions. The change also shifts the most consequential advocacy to the pre‑Wells stage, making early engagement with staff and senior leadership more critical. Ultimately, the real impact will hinge on how rigorously the new approval process is enforced.