Authored by: Judy Kwan, Danielle Van Wert and Paul Rugani.
2016 was a high-water mark for SEC enforcement activity;
however, with the uncertainties associated with the new
administration's enforcement regime, we could be seeing a
downturn going forward. According to a
recent report issued by the NYU Pollack Center for Law &
Business and Cornerstone Research, the SEC's 2016 fiscal year
(spanning October 1, 2015 – September 30, 2016) saw the
highest number of enforcement actions brought against public
companies and their subsidiaries since 2009, the year the Pollack
Center and Cornerstone Research first began tracking information on
such actions. The 92 actions brought against public companies
and their subsidiaries last year is more than double the level of
enforcement activity from just three years ago and represents the
latest in a continuing upward trend of enforcement actions.
Also consistent with recent trends, the vast majority of these
actions have been
