A recent study finds that SEC enforcement activity through the third quarter of 2016 has declined 8 percent from 2015 levels. While the study concedes that most enforcement actions are filed during the fourth quarter, the 299 that would be necessary to match 2015 levels would be unprecedented.
The survey finds that 15% of all enforcement actions filed this year have been accounting related. Additionally, the SEC continues to favor administrative proceedings, filing 81% of enforcement cases in administrative court. Through three quarters in 2016, “follow on” administrative proceedings accounted for 23% of all enforcement activity, an increase from 16% in 2015. Follow on proceedings are not new activity, but instead are “administrative proceedings seeking bars against individuals based on criminal convictions, civil injunctions, or other orders.”