A New SEC Enforcement Direction For 2014

Each year, the SEC puts on its most informative conference of the year: The SEC Speaks.  During the course of the two-day conference, held this year on February 21 and 22, the Chair and each Commissioner, as well as the most senior staff of each division of the SEC, provide their thoughts and insights into the most pressing issues currently being considered by the Commission. One of the annual highlights of the conference is the discussion of the enforcement program and its successes, failures, initiatives and priorities. Last year we noted that changes at the senior levels of the Commission and the Division of Enforcement caused the staff to remain vague in outlining priorities and initiatives (See http://www.mofo.com/files/Uploads/Images/130305-SEC-Enforcement-Initiatives.pdf). This year, with new management in place, the staff had no difficulty announcing that change is in the works. From new enforcement priorities to changes in long-lived enforcement policies, and