Overview
- The SEC Division of Enforcement published a revised Enforcement Manual on Feb. 24, 2026, its first comprehensive refresh in roughly eight to nine years.
- The Wells process is now standardized: targets ordinarily receive four weeks to respond, a meeting is set within four weeks with senior leadership present, and staff must share salient, probative evidence.
- Enforcement staff must obtain the Enforcement Director’s approval to issue or decline a Wells notice, action memos must objectively address evidentiary risks and defense arguments, and White Papers are to be provided to the Commission.
- The Commission restored simultaneous consideration of settlements and related waiver requests, clarified a five‑business‑day election if a waiver is denied, and expanded cooperation and remediation guidance that can include zero‑penalty outcomes.
- New procedures tighten criminal referrals and tolling agreements, resource priorities highlight particularly vulnerable investors and new “Top 5” matters, and the SEC plans annual updates as practitioners assess the practical impact.