SEC announces significant updates to enforcement manual

On February 24, the SEC’s Division of Enforcement announced numerous revisions to its Enforcement Manual, marking its first significant revision to the manual since 2017. The SEC stated that future revisions to the manual will be posted on an annual basis. Among the highlighted changes are: (i) formalizing the “Wells” process, the SEC’s informal process giving those facing a potential enforcement recommendation a chance to present their position to staff before action is decided;... By: Orrick, Herrington & Sutcliffe LLP