SEC Enforcement Actions

What Changed

This announcement reflects structural reforms rather than new substantive regulations: Replacement of Regional Directors with Deputy Directors, centralizing reporting from local offices (e.g., Boston, Fort Worth, Atlanta) and specialized units directly to headquarters-led Deputy Directors. Enhanced supervision of enforcement decisions, aiming for consistency and reduced regional variations in handling investigations. Complements parallel Wells process reforms under Chairman Paul Atkins, includin

What You Need To Do

• Review and update internal protocols for SEC investigations to align with centralized reporting structures, anticipating uniform standards across regions
• Train legal/compliance staff on refined Wells process (e
• Monitor upcoming SEC communications for Enforcement Director Judge Margaret Ryan's guidance on fraud-focused priorities
• Assess current or potential matters for earlier engagement with Deputy Directors on case theories and resolutions

Key Dates

References

• [1] jdsupra.com
• [2] dlapiper.com
• [3] mwe.com
• [4] corpgov.law.harvard.edu
• [5] foley.com
• [6] skadden.com
• [7] sec.gov
• [8] capx.cooley.com

What Changed

Raise the RAUM threshold for RIAs to qualify as small entities from $25 million to $1 billion, with conforming changes for control affiliates. Increase the net asset threshold for investment companies from $50 million to $10 billion. Update aggregation of related funds from "group of related investment companies" to "family of investment companies" as defined in Form N-CEN for easier identification. Introduce inflation adjustments to thresholds every 10 years via SEC order, without formal rulema

What You Need To Do

• Submit public comments by the deadline to influence thresholds, alternatives (e
• Monitor Federal Register for exact publication and comment instructions; review proposed rule and fact sheet on SEC site (https://www
• Assess internal status
• No immediate compliance changes, as this affects SEC rulemaking process only; prepare for potential indirect impacts via future rules

Key Dates

References

• [1] sewkis.com
• [2] regulatoryandcompliance.com
• [3] jdsupra.com
• [4] sec.gov
• [5] freewritings.law
• [6] sec.gov
• [7] questce.com
• [8] sullivanlaw.com

What Changed

There are no main regulatory changes, new requirements, or policy updates in this announcement; it is solely a personnel departure notice with no substantive regulatory implications. #

What You Need To Do

• related delays and monitor for successor announcements via https://www

Key Dates

References

• [1] sifma.org
• [2] sec.gov
• [3] securitiesdocket.com
• [4] sec.gov
• [5] ali.org
• [6] jonesday.com

What Changed

This announcement itself introduces no new regulatory changes or requirements; it is a personnel update. However, it occurs amid broader Enforcement Division restructuring, including: Consolidation from one Deputy Director to four (three regional: Northeast, Southeast, West; one for specialized units), reducing reporting lines for a more unified nationwide enforcement program. Rescission in March 2025 of delegated authority for the Enforcement Director to issue formal orders of investigation, no

What You Need To Do

• Review ongoing Northeast Regional Office investigations for potential leadership changes and engage early with new deputies on cooperation opportunities
• Enhance internal self-reporting and remediation protocols to align with Enforcement's stated rewards for cooperation and robust Wells processes
• Update compliance training on restructured reporting lines and Commission-authorized formal orders, ensuring defenses stick to established securities laws rather than novel theories
• Monitor SEC staff directory for replacement announcements, such as potential roles for Samuel Waldon or others in the Northeast

Key Dates

References

• [1] mcguirewoods.com
• [2] sec.gov
• [3] dechert.com
• [4] corpgov.law.harvard.edu
• [5] skadden.com
• [6] perkinscoie.com
• [7] morganlewis.com
• [8] clearygottlieb.com