Recent commentary by Diana Tani, an Assistant Regional Director
for the SEC, at the Securities Enforcement West web conference
emphasized the agency's focus on data-driven investigations.
Two areas targeted for recent enforcement are manipulations to
achieve earnings per share (EPS) estimates and undisclosed
executive compensation, especially as related to executives'
usage of corporate aircraft.
Recent enforcement actions suggest that the SEC is targeting
quarterly public filings. Quarterly reports are not subject to the
same accounting oversight as annual reports. Recent cases
highlighted by the agency as examples of data-based enforcement
actions suggest that the SEC's focus with data-based
investigations is on quarterly reports and other areas where
manipulation may be more likely to occur.
