SEC Roundup 96: Inside the 2026 Enforcement Manual Updates скачать в хорошем качестве

SEC Roundup 96: Inside the 2026 Enforcement Manual Updates

The internal "user manual" for SEC attorneys has finally been refreshed to reflect the leadership of Chairman Paul Atkins and Enforcement Director Judge Meg Ryan. In this episode, Nick Morgan and Tom Zaccaro sit down with Lori Echavarria, a 15-year veteran of the Commission and partner at WilmerHale, to discuss why this non-binding document is such a critical bellwether for defense practitioners. In this episode, we cover: • The Wells Process Shift: Moving from a two-week to a four-week formal response period. • Centralized Oversight: Why the Division Director must now personally approve every Wells notice nationwide. • The Cooperation Carrot: New written guidance on how remediation and "fulsome" cooperation can eliminate monetary penalties. • Simultaneous Waivers: Reverting to the efficient practice of considering "Bad Actor" waivers at the same time as settlements. • File Transparency: The new instruction for staff to be "forthcoming" with their investigative files during the Wells stage.