The SEC’s new cooperation tools have impacted a number of actions. In four cases, as discussed in Part I of this article, the Commission entered into agreements under which it either chose to prosecute or deferred prosecution with a view …

The Impact of the New Commission Cooperation Initiatives – Part II Read More »

Cooperation was a major tenant in the retooling of the SEC’s enforcement program. Borrowing heavily from the Department of Justice, the Commission announced proposals to use non-prosecution agreements and deferred prosecution agreements to encourage cooperation in 2010. While the emphasis …

The Impact of the New Commission Cooperation Initiatives – Part I. Read More »